Tarbox Corp. v. Commissioner
United States Tax Court
Held, that petitioner's failure to file a personal holding company return was not due to reasonable cause, and the delinquency penalty was properly imposed.
1Opinion of the Court
OPINION.
Akundell, Judge-.
The only issue in this case is whether there was reasonable cause for petitioner’s failure to file a personal holding company return within the time prescribed by law. In support of its contention that there was, petitioner relies upon the fact that its president and sole stockholder first consulted his attorney and then engaged an accountant to prepare petitioner’s tax return, and that he acted in complete reliance upon them.
Clearly this is not a case where petitioner’s status as a personal holding company was in substantial doubt and its officer or officers, after a…
2Cases cited3 opinions
- Commissioner v. Lane-Wells Co.Supreme Court of the United States · 1944
- Germantown Trust Co. v. CommissionerSupreme Court of the United States · 1940
- Dayton Bronze Bearing Co. v. GilliganCourt of Appeals for the Sixth Circuit · 1922
3Cited by44 opinions
- Hatfried, Inc. v. Commissioner of Internal Rev.Court of Appeals for the Third Circuit · 1947
- Bouche v. CommissionerUnited States Tax Court · 1952
- Anderson v. CommissionerUnited States Tax Court · 1956
- Joyce v. CommissionerUnited States Tax Court · 1955
- Hermax Co. v. CommissionerUnited States Tax Court · 1948
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