American Ideal Cleaning Co. v. Commissioner
United States Board of Tax Appeals
Respondent, in the notice of deficiency, determined fraud penalties in the amount of 50 percent of the deficiency as to each of the years in controversy. He did not, however, determine therein that there was due from the petitioner a 5 percent penalty for negligence. In its petition the petitioner raised no question as to its liability for the deficiencies in tax, but contested the fraud penalties.
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Respondent, in the notice of deficiency, determined fraud penalties in the amount of 50 percent of the deficiency as to each of the years in controversy. He did not, however, determine therein that there was due from the petitioner a 5 percent penalty for negligence. In its petition the petitioner raised no question as to its liability for the deficiencies in tax, but contested the fraud penalties. At the hearing counsel for the respondent offered no evidence to sustain the fraud penalties, but filed an amended answer praying that the Board add to the deficiencies in tax such penalty as is…
1Opinion of the Court
OPINION.
McMahon :
The petitioner is a corporation, with its principal office at Chicago, Illinois.
The respondent determined that the following- deficiencies in income tax and penalties are due from the petitioner:
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In the petition the petitioner alleges that the respondent erred in asserting 50 percent fraud penalities as above stated. In the petition it is stated, however, that the tax is not disputed and that the appeal pertains solely to the fraud penalties. In his original answer the respondent denied all the allegations of the petitioner except the preliminary allegations.
This…
2Cases cited1 opinion
- KERBAUCH v. COMMISSIONERUnited States Board of Tax Appeals · 1934
3Cited by7 opinions
- Sanderling, Inc. v. CommissionerUnited States Tax Court · 1976
- Lord v. CommissionerUnited States Tax Court · 1973
- American Ideal Cleaning Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Franklin v. CommissionerUnited States Board of Tax Appeals · 1936
- Lord v. CommissionerUnited States Tax Court · 1973
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