Genesee Valley Gas Co. v. Commissioner
United States Tax Court
Petitioner, a personal holding company within the meaning of section 501, Internal Revenue Code, failed to file a surtax return as such. Held, that such failure was due to willful neglect and not to reasonable cause and that accordingly petitioner is liable for the statutory penalty for failing to file such return.
1Opinion of the Court
OPINION.
Hill, Judge:
Ifc is stipulated that “petitioner was a personal holding company in each of the taxable years 1941 and 1942 within the meaning of section 501 of the Internal Revenue Code and is liable for the personal holding company surtax on its undistributed sub-Chapter A net income for each of said years as provided by section 500 of the Internal Revenue Code.”
The only issue we have to decide is whether petitioner is liable for the statutory penalties for failure to file personal holding company surtax returns for the years here involved.
Petitioner contends that such failure was due…
2Cases cited2 opinions
- P. Dougherty Co. v. CommissionerUnited States Tax Court · 1945
- Home Guaranty Abstract Co. v. CommissionerUnited States Tax Court · 1947
3Cited by9 opinions
- Haywood Lumber & M. Co. v. CommissionerUnited States Tax Court · 1949
- Lawrence Block Co. v. CommissionerUnited States Tax Court · 1949
- Mayflower Inv. Co. v. CommissionerUnited States Tax Court · 1955
- Genesee Valley Gas Co. v. CommissionerUnited States Tax Court · 1948
- Haywood Lumber & M. Co. v. CommissionerUnited States Tax Court · 1949
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