Garwood Irrigation Company - Page 7

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          clearly “2 percentage points in the case of a corporation”.                 
          While we agree with petitioner that “corporation” in the flush              
          language means C corporation as a result of the cross-reference             
          to subsection (c)(3), we do not find that cross-reference                   
          applicable to the operation of subsection (a)(1)(B) and are left            
          with the word “corporation” with no cross-reference.  The general           
          definition of “corporation” in section 7701(a)(3) and section               
          301.7701-2(b)(1), Proced. & Admin. Regs., does not distinguish              
          between C and S corporations.  Accordingly, we find petitioner is           
          entitled to an additional 2 percentage points interest, rather              
          than the 3 percentage points for noncorporate taxpayers.                    
               To reflect the foregoing,                                              

                                                  An appropriate order                
                                             will be entered.                         





















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