Bouche v. Commissioner
United States Tax Court
Petitioner filed no declaration of estimated tax for the year 1947. For such omission, respondent determined petitioner to be subject to an addition to his tax for that year pursuant to section 294 (d) (1) (A), I. R. C.Held: No reasonable cause existed for petitioner's failure to file the requisite declaration and respondent is sustained in his determination.
1Opinion of the Court
OPINION.
Van Fossan, Judge:
Petitioner failed to file a declaration of estimated tax for the taxable year 1947 as required by section 58 (a), Internal Revenue Code.1 Respondent has accordingly determined that petitioner is subject to an addition to his tax for that year pursuant to section 294 (d) (1) (A) of the Code.2
An examination of the statutes reveals that the provisions requiring the filing of a declaration of estimated tax are no less mandatory than those requiring the filing of final income tax returns. The sections of the Code so providing are clear and explicit. They specify which…
2Cases cited3 opinions
- Tarbox Corp. v. CommissionerUnited States Tax Court · 1946
- Hermax Co. v. CommissionerUnited States Tax Court · 1948
- Stephan v. CommissionerUnited States Tax Court · 1951
3Cited by59 opinions
- Walter H. Kaltreider and Irene C. Kaltreider v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
- Durovic v. CommissionerUnited States Tax Court · 1970
- Elliott v. CommissionerUnited States Tax Court · 1963
- Kaltreider v. CommissionerUnited States Tax Court · 1957
- Abbott v. CommissionerUnited States Tax Court · 1957
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