Marbut v. Commissioner
United States Tax Court
Petitioners did not file a declaration of estimated tax for the taxable years 1950 and 1951. They did file joint individual income tax returns for those years on March 15, 1951, and March 17, 1952, respectively. On January 15, 1954, petitioners filed a "Consent" agreeing that the amount of "any" income tax due under "any return" for the year 1950 may be assessed at any time on or before June 30, 1955, and later, if a notice of deficiency in tax is sent before that date.
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Petitioners did not file a declaration of estimated tax for the taxable years 1950 and 1951. They did file joint individual income tax returns for those years on March 15, 1951, and March 17, 1952, respectively. On January 15, 1954, petitioners filed a "Consent" agreeing that the amount of "any" income tax due under "any return" for the year 1950 may be assessed at any time on or before June 30, 1955, and later, if a notice of deficiency in tax is sent before that date. On September 24, 1954, respondent mailed petitioners a notice of deficiencies in additions to income tax for 1950 and 1951,…
1Opinion of the Court
Arundell, Judge:
Respondent determined deficiencies in additions to income tax for the taxable years ended December 31,1950 and 1951, in amounts as follows:
Deficiencies in additions under Sec. 294 Sec. 294 Tear (d) (1) (A) (d) (2)
1950_$2,243. 02 $1,495. 35
1951_ 2,391. 52 1, 594.35
Several issues are raised based on petitioners’ contention that respondent’s conduct over the years was such as to estop him from making the foregoing determination; that petitioners’ failure to file declarations of estimated tax does not serve to permit the Commissioner to determine that petitioners underestimated…
2Cases cited17 opinions
- Fuller v. CommissionerUnited States Tax Court · 1953
- Jones v. CommissionerUnited States Tax Court · 1956
- Hartley v. CommissionerUnited States Tax Court · 1954
- Patchen v. CommissionerUnited States Tax Court · 1956
- Bouche v. CommissionerUnited States Tax Court · 1952
12 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Fred N. Acker v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1958
- Josef C. Patchen and Aleyne E. Patchen v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1958
- England v. CommissionerUnited States Tax Court · 1960
- Ralph C. Granquist, District Director of Internal Revenue for the District of Oregon v. Margaret HacklemanCourt of Appeals for the Ninth Circuit · 1959
- Picard v. CommissionerUnited States Tax Court · 1957
12 more not listed; retrieve them via the Exa API.