In addition to the penalty imposed by section
7203 (relating to willful failure to file return, supply information, or pay tax), if any S corporation required to file a return under section
6037 for any taxable year—
such S corporation shall be liable for a penalty determined under subsection (b) for each month (or fraction thereof) during which such failure continues (but not to exceed 12 months), unless it is shown that such failure is due to reasonable cause.