to deference. 7 . See, e.g., In re Craddock, 149 F.3d 1249, 1255 (10th Cir. 1998) (requiring individual plaintiff to prove inability to file tax returns in addition to ordinary business prudence); Va-len Mfg. v. United States, 90 F.3d 1190, 1193 (6th Cir. 1996), (finding that the ability “to forward immediately to the IRS the necessary payments, including penalfles," meant that there was ho disability and thérefore no reasonable cause); Conklin Bros, of Santa Rosa v. United States, 986 F.2d 315, 318-19 (9th Cir. 1993) (finding that a corporation was not excused from a tax penalty where, despite exercising ordinary business prudence, the corporation was -not disabled from complying with its tax obligations). See also In re American Biomaterials Corp., 954 F.2d 919, 921 (3d ■ Cir. 1992) (<HOLDING>). 8 . Compare, e.g., Knappe v. United States,
holding that corporation and sole owner of corporation were separate legal entities and corporation was not party to contract signed by owner in individual capacity holding a corporation excused from a tax penalty when the sole people in charge of filing and paying taxes were embezzling funds from the corporation thus disabling the corporations ability to pay holding that the funds in the privatelyheld corporations account belonged to the corporation not to the individuals who owned the corporation and expressly stating that directors officers and shareholders of a corporation do not have standing to claim an ownership interest in corporate property in their individual capacities they must state a claim in the corporate name holding that resident shareholder of s corporation is eligible for tax credit for taxes paid by corporation in another state and noting that this conclusion is consistent with the internal revenue code which provides that shareholders of an s corporation are entitled to a foreign tax credit for their share of foreign income tax paid by an s corporation holding that claims of corporation vest in corporation