- 7 - 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.Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011