Newsom v. Commissioner
United States Tax Court
Addition to tax for substantial underestimate of estimated tax as sole basis for issuance of statutory notice of deficiency held proper determination of a deficiency within meaning of section 271 (a) so as to confer Tax Court jurisdiction under section 272 (a) (1), Internal Revenue Code.
1Opinion of the Court
OPINION.
OppeR, Judge:
Respondent determined a “deficiency of penalty” of $1,627.92 for the year 1948 against petitioners for substantial understatement of estimated income tax under section 294 (d) (2) of the Internal Revenue Code. There was no other “deficiency” determined in the statutory notice. Petitioners moved to dismiss their own petition on the ground that the Tax Court has no jurisdiction to consider it. No evidence was introduced at the hearing.
The parties are in agreement that the single question for our decision is whether under the present circumstances the Tax Court has…
2Cases cited9 opinions
- Smith v. CommissionerUnited States Tax Court · 1953
- Bouche v. CommissionerUnited States Tax Court · 1952
- Eck v. CommissionerUnited States Tax Court · 1951
- United States v. Erie Forge Co.Court of Appeals for the Third Circuit · 1951
- Middleton v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1952
4 more not listed; retrieve them via the Exa API.
3Cited by24 opinions
- Brown v. CommissionerUnited States Tax Court · 1982
- George Olshausen v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1960
- Estate of Di Rezza v. CommissionerUnited States Tax Court · 1982
- Ralph C. Granquist, District Director of Internal Revenue for the District of Oregon v. Margaret HacklemanCourt of Appeals for the Ninth Circuit · 1959
- Estate of Leyman v. CommissionerUnited States Tax Court · 1963
19 more not listed; retrieve them via the Exa API.