Hanby v. Commissioner of Internal Revenue

SOPER, Circuit Judge.

A petition was filed by tbe taxpayer to review a decision of tbe Board of Tax Appeals affirming tbe Commissioner’s determination of additional income and excess profits taxes for tbe years 1917, 1918, 1919, 1920, and 1921. Tbe sum of the deficiencies of tbe taxes in these years, as so approved, is $22,829.-64, to which penalties in the amount of $20,-556.35 have been added. For the year 1917 there was imposed under R. S. § 3176, as amended by section 16 of the Revenue Act of 1916 (39 Stat. 756, 775), a penalty of 50 per cent, of the excess profits tax, for failure to make…