Legal Opinion
Southeastern Finance Co. v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided February 5, 1946No. 11504PublishedCited by 72 opinions
1Opinion of the Court
McCORD, Circuit Judge.
This appeal involves delinquency penalties for taxpayer’s failure to file timely personal holding company returns for the years 1940 and 1941.
The question is: Did taxpayer establish “reasonable cause” for its failure to file timely personal holding company returns within the meaning of Section 291 of the Internal Revenue Code, 26 U.S.C.A. Int. Rev. Code, § 291 ?
Taxpayer was a corporation organized under the Florida laws on August 31, 1939. It was engaged in the business of discounting and rediscounting conditional sales contracts, and supporting installment notes,…
2Cases cited5 opinions
- Dobson v. CommissionerSupreme Court of the United States · 1944
- Commissioner v. Lane-Wells Co.Supreme Court of the United States · 1944
- Commissioner v. Scottish American Investment Co.Supreme Court of the United States · 1945
- West Side Tennis Club v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1940
- Girard Inv. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1941
3Cited by72 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
- Paula Constr. Co. v. CommissionerUnited States Tax Court · 1972
- Haywood Lumber & Mining Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1950
- Beck Chemical Equipment Corp. v. CommissionerUnited States Tax Court · 1957
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