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The Tax Court, in Garwood Irrigation Co. v. Commissioner, 126 T.C. No. 12 (May 1, 2006), held that the lower corporate rate of overpayment interest set forth in the flush language of section 6621(a)(1) does not apply to Subchapter S corporations.
Also in this issue:
· Large Corporate Overpayment Interest Limitation Does Not Apply to S Corporations
· IRS Clarifies “Substantial Omission” Calculation as Applied to Partners
· Temporary Change of Address for Certain Hand-Delivered Documents to IRS
· Tax Controversy Update: Chief Counsel Announces Changes to IRS Legal Advice
· Recent Guidance
· Dbriefs: Tax Strategies
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