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.
