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Internal Revenue Code Sec. 7508
Interest on the deliquent payroll taxes of a partnership whose principal is serving in a combat zone is *NOT* suspended for the period the partner serves in a combat zone.
A partnership whose principal partner was an individual serving in a combat zone requested abatement of interest on the partnership's payroll tax liabilities for two quarters. The payroll taxes were not timely filed because the individual was serving in a combat xone at the time the liabilities were due. The time period for filing and paying the partnership's payroll tax liability occurred *BEFORE* August 25, 2005, the effective date of the Katrina Emergency Relief Act (KETRA)of 2005 amendments to section 7508.
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The Office of the Chief Counsel further advised that even if the amendment under KETRA applies retroactively to permit the suspension of interest on payroll taxe liabilities, there could be no suspension of interest because the taxpayer is a partnership , and partnerships are not individuals who may serve in, or serve in support of a combat zone.
Chief Councel Memo (CCM 200613030)
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Ant this is how the *ies support our troups???????
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