ATL & Sons Holdings, Inc. v. Commissioner: Late Filing Penalty Applied to S Corp Where Shareholders Obtained Own Filing Extensions; No Supervisory Approval was Needed

In ATL & Sons Holdings, Inc. v. Commissioner, the Tax Court has concluded that an S corporation was liable for the Code Sec. 6699 penalty for failure to timely file its return, even though its shareholders obtained an extension to file their own tax return (and timely did so). The Court further determined that as the penalty was automatically calculated through electronic means no supervisory approval was needed to impose the penalty.

See full opinion at:  ATL & Sons Holdings, Inc. v. Commissioner (2019) 152 TC No. 8.

Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out /  Change )

Google photo

You are commenting using your Google account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s