Legal Opinion
Haywood Lumber & Mining Co. v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided January 4, 1950No. 21468_1PublishedCited by 120 opinions
1Opinion of the Court
SWAN, Circuit Judge.
The taxpayer is a personal holding company. The Commissioner determined deficiencies in personal holding company surtaxes for the years 1941 and 1942 and added thereto a 25% penalty, pursuant to § 291 of the Internal Revenue Code, for petitioner’s failure to file personal holding company returns for those years. The sole question presented to the Tax Court and likewise here is whether the taxpayer’s failure to file personal holding company returns for the years in suit was “due to reasonable cause and not due to willful neglect”. 1 The Tax Court held that it was not due to…
2Cases cited11 opinions
- Hatfried, Inc. v. Commissioner of Internal Rev.Court of Appeals for the Third Circuit · 1947
- Paymer v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1945
- Southeastern Finance Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1946
- Girard Inv. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1941
- Orient Investment & Finance Co. v. COMMISSIONER OF IRCourt of Appeals for the D.C. Circuit · 1948
6 more not listed; retrieve them via the Exa API.
3Cited by120 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- Crocker v. CommissionerUnited States Tax Court · 1989
- Davis Et Ux. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1950
- Sanderling, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1978
- Duttenhofer v. CommissionerUnited States Tax Court · 1967
115 more not listed; retrieve them via the Exa API.