T.C. Memo. 2004-43 UNITED STATES TAX COURT CHARLOTTE’S OFFICE BOUTIQUE, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent* Docket No. 5077-01. Filed February 25, 2004. In Charlotte’s Office Boutique, Inc. v. Commissioner, 121 T.C. 89 (2003), an employment tax case brought under sec. 7436(a), I.R.C., we held that P is liable for unreported 1995 through 1998 employment taxes and certain additions thereto under secs. 6651(a)(1) and 6656, I.R.C. P now asserts that this Court lacked jurisdiction to redetermine the referenced additions to tax. P argues primarily that section 7436(a), I.R.C., by its terms allows the Court to redetermine only “the proper amount of employment tax” and not any additions thereto. P argues alternatively that sec. 6651(a)(1), I.R.C., by its terms does not allow the Court to redetermine an addition to tax under that section in the case of a failure to file the returns at issue; namely, Forms 941, Employer’s *This Supplemental Memorandum Opinion supplements our prior Opinion in Charlotte’s Office Boutique, Inc. v. Commissioner, 121 T.C. 89 (2003).Page: 1 2 3 4 5 6 7 8 Next
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