Daily Tax Report ®

Case: Penalty Determination Upheld Absent Reasonable Cause (T.C. Memo) (IRC §6651)

Jan. 14, 2020, 5:00 AM

Penalty determination upheld where assessment was lawful and Corporation could not establish reasonable cause for not paying the taxes when due, the U.S. Tax Court held in a memorandum opinion. As a result of an audit of Corporation, the IRS disallowed a tax code Section 481A deduction. Corporation was informed that an amended return wouldn’t be accepted, but Corporation filed one anyway claiming that the deduction was inadvertently reported incorrectly and reflecting an increase in income, as well as adjustments to depreciation and accumulated depreciation. Corporation didn’t include a payment for the additional liability with the amended return. Corporation...

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