American Ideal Cleaning Co. v. Commissioner
United States Board of Tax Appeals
Respondent, in the notice of deficiency, determined fraud penalties in the amount of 50 percent of the deficiency as to each of the years in controversy. He did not, however, determine therein that there was due from the petitioner a 5 percent penalty for negligence. In its petition the petitioner raised no question as to its liability for the deficiencies in tax, but contested the fraud penalties.
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Respondent, in the notice of deficiency, determined fraud penalties in the amount of 50 percent of the deficiency as to each of the years in controversy. He did not, however, determine therein that there was due from the petitioner a 5 percent penalty for negligence. In its petition the petitioner raised no question as to its liability for the deficiencies in tax, but contested the fraud penalties. At the hearing counsel for the respondent offered no evidence to sustain the fraud penalties, but filed an amended answer praying that the Board add to the deficiencies in tax such penalty as is…
1Opinion of the Court
AMERICAN IDEAL CLEANING COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
American Ideal Cleaning Co. v. Commissioner
Docket No. 49205.
United States Board of Tax Appeals
30 B.T.A. 529; 1934 BTA LEXIS 1303;
April 27, 1934, Promulgated
Respondent, in the notice of deficiency, determined fraud penalties in the amount of 50 percent of the deficiency as to each of the years in controversy. He did not, however, determine therein that there was due from the petitioner a 5 percent penalty for negligence. In its petition the petitioner raised no question as to its liability for the…
2Cases cited1 opinion
- American Ideal Cleaning Co. v. CommissionerUnited States Board of Tax Appeals · 1934