Garwood Irrigation Co. v. Comm'r
United States Tax Court
P, an S corporation, is due an overpayment that exceeds $ 10,000. R computes that overpayment using the Federal short-term rate plus 0.5 percentage point according to R's reading of sec. 6621(a)(1), I.R.C. P maintains that it should not be treated as a corporation for purposes of determining the applicable rate because of its S corporation election. P's position is based upon sec. 6621(c)(3), I.R.C., which is cross-referenced in sec. 6621(a)(1), I.R.C.
Read the full summary
P, an S corporation, is due an overpayment that exceeds $ 10,000. R computes that overpayment using the Federal short-term rate plus 0.5 percentage point according to R's reading of sec. 6621(a)(1), I.R.C. P maintains that it should not be treated as a corporation for purposes of determining the applicable rate because of its S corporation election. P's position is based upon sec. 6621(c)(3), I.R.C., which is cross-referenced in sec. 6621(a)(1), I.R.C. Held: The lower corporate rate set forth in the flush language of sec. 6621(a)(1), I.R.C., applies to C corporations, and P is entitled to the…
1Opinion of the Court
GARWOOD IRRIGATION COMPANY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Garwood Irrigation Co. v. Comm'r
No. 1459-03
United States Tax Court
126 T.C. 233; 2006 U.S. Tax Ct. LEXIS 12; 126 T.C. No. 12;
May 1, 2006, Filed
Garwood Irrigation Co. v. Comm'r, T.C. Memo 2004-195, 2004 Tax Ct. Memo LEXIS 200 (T.C., 2004)
P, an S corporation, is due an overpayment that exceeds $ 10,000.
R computes that overpayment using the Federal short-term rate
plus 0.5 percentage point according to R's reading of
sec. 6621(a)(1), I.R.C. P maintains that it should not be treated as
a corporation for purposes of…
2Cases cited3 opinions
- Reynolds v. CooperSupreme Court of the United States · 1934
- Garwood Irrigation Co. v. Comm'rUnited States Tax Court · 2006
- Garwood Irrigation Co. v. Comm'rUnited States Tax Court · 2004