Fran Corp. v. United States

COTE, District Judge:

Plaintiff-Appellant Fran Coip. (“Fran” or “Taxpayer”) appeals from a March 2, 1998 judgment entered in the United States District Court for the Southern District of New York (Charles L. Brieant, District Judge), granting the United States’ motion for summary judgment and denying plaintiffs cross-motion for summary judgment in its action seeking a refund of tax penalties. Plaintiff argued below, and now urges on appeal, that it had “reasonable cause” for its late payment and deposit of employment taxes under 26 U.S.C. §§ 6651(a)(2) and 6656(a), respectively, and thus…