George Olshausen v. Commissioner of Internal Revenue

ORR, Circuit Judge.

For failure to file declarations of estimated tax for the years 1952 and 1953, the Commissioner of Internal Revenue pursuant to § 294 of the Internal Revenue Code of 1939, 26 U.S.C.A. § 294, assessed additions to petitioner’s tax as penalties for said failure 1 ******and also for substantial underestimate of estimated tax. 2 The Tax Court sustained the findings of the Commissioner and taxpayer petitions for review.

At the time of argument and submission of the case, there was pending for hearing before the Supreme Court of the United States the case of Commissioner of…