On April 26, 2021, the Tax Court issued a Memorandum Opinion in the case of Plentywood Drug Inc. v. Commissioner (T.C. Memo. 2021-45). The primary issues presented in Plentywood Drug, Inc. were whether the petitioner’s owners received “fair rent” or constructive dividends for the rental of the petitioner’s drug store, and whether the petitioner (a corporation) satisfied its burden to show that the IRS failed to receive prior supervisory approval for the accuracy-related penalties at issue under IRC § 6751(b)(1). Background to Plentywood Drug Inc. v. Commissioner Up in Big Sky country, there is the town of Plentywood, Montana.  The town is sparsely populated, even by Montana standards, at approximately 2 people per square mile.  Plentywood Drugs serves a four-county area (approximately 7,200 square miles, or 14,400 people).  There is also a post office in Plentywood, which will come into play when the IRS came a’knockin’ and cast aspersions towards…