Cooper v. Commissioner
United States Tax Court
Upon the evidence it is held that the respondent did not err in determining that petitioners are liable for an addition to tax as provided by section 294 (d) (1) (A) of the Internal Revenue Code of 1939 for failure to file a declaration of estimated tax for the taxable year 1950 as provided by section 58 of the Code.
1Opinion of the Court
OPINION.
Arundell, Judge:
Section 58 1 of the 1939 Code plainly sets forth who shall make a declaration of estimated tax, the time and place for filing such declaration, when amendments of a declaration may be filed, and the effect of filing a completed return of income on or before January 15 of the succeeding taxable year. Section 2942 of the 1939 Code provides that there shall be added to the tax certain “additions” for failure to make and file a declaration of estimated tax within the time prescribed unless such failure is shown “to be due to reasonable cause and not to willful neglect.”
Peti…
2Cases cited3 opinions
- Bouche v. CommissionerUnited States Tax Court · 1952
- Joyce v. CommissionerUnited States Tax Court · 1955
- Fischer v. CommissionerUnited States Tax Court · 1955
3Cited by11 opinions
- Pinkerton v. CommissionerUnited States Tax Court · 1957
- Maxey v. CommissionerUnited States Tax Court · 1956
- Potter v. Comm'rUnited States Tax Court · 1956
- Potter v. CommissionerUnited States Tax Court · 1956
- Stewart v. United StatesDistrict Court, S.D. New York · 1967
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