- 97 - Bulletin”. Sec. 1.6662-3(a), Income Tax Regs. The section 6662(a) accuracy-related penalty will not apply to such a position where the position has a realistic possibility of being sustained on its merits. Sec. 1.6662-3(a), Income Tax Regs.75 Petitioners have not indicated which revenue ruling or notice, if any, their positions contradict. Accordingly, we decline to give this argument further consideration. B. Petitioners’ Second Theory Petitioners assert that the “voluminous record” and the “mandatory national office review” of respondent’s brief illustrate the complex and technical nature of the issues. For this reason, petitioners argue, the section 6662(a) accuracy- related penalties do not apply. Although we agree with petitioners that the state of the record in this case suggests that the parties had difficulties with the issues, we disagree that the three issues for which respondent determined penalties are actually complex or technical in nature. Menards’s payments of both the TMI expenses and interest accrued on Mr. Menard’s loans to the company were straightforward transactions. We reject petitioners’ argument. 75Sec. 1.6694-2(b), Income Tax Regs. contains the realistic possibility standard. See sec. 1.6662-3(a), Income Tax Regs.Page: Previous 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100 101 102 Next
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