Legal Opinion

Robinson's Dairy, Inc. v. Commissioner of Internal Revenue

Court of Appeals for the Tenth Circuit

Decided March 27, 1962No. 6802_1PublishedCited by 65 opinions

1Opinion of the Court

PICKETT, Circuit Judge.

This is a petition to review a Tax Court decision holding that the petition er was not entitled to the benefits of an amendment to the Excess Profits Tax Act of 1950 1 relating to new corporations, and upholding the assessment of penalties under both § 291(a) and § 293(a), 26 U.S.C.A. §§ 291(a), 293(a) 2 for failure to file timely tax returns for the years in question, which was found to be due to negligence. With respect to the applicability of § 430(e), granting relief to new businesses, the taxpayer contends that it has met, in substance, the requirements of the…

2Cases cited3 opinions

  1. Sanders v. CommissionerCourt of Appeals for the Tenth Circuit · 1955
  2. Chimchirian v. HelveringCourt of Appeals for the D.C. Circuit · 1942
  3. Robert L. Phinney v. Tuboscope CompanyCourt of Appeals for the Fifth Circuit · 1959

3Cited by65 opinions

  1. Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
  2. Logan Lumber Company v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1966
  3. Crocker v. CommissionerUnited States Tax Court · 1989
  4. Emmons v. CommissionerUnited States Tax Court · 1989
  5. Thompson v. CommissionerUnited States Tax Court · 1982

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