by circumstance

References in periodicals archive ?
Reasonable cause can exist only when "(1) the taxpayer has made reasonable efforts to protect the trust funds, but (2) those efforts have been frustrated by circumstances outside the taxpayer's control." The court noted that, although the Fifth Circuit has "conceptually recognized" the reasonable cause exception under Sec.
In the three reserve maintenance periods completed since the August meeting, adjustment plus seasonal borrowing averaged about $800 million, an amount inflated by circumstances that gave rise to sharply higher federal funds rates and unusually heavy adjustment credit extensions on the final day of each of these maintenance periods.