Legal Opinion

Haywood Lumber & M. Co. v. Commissioner

United States Tax Court

Decided May 11, 1949No. Docket No. 15921Published

Petitioner failed to file a personal holding company surtax return in 1941 and 1942, though it was a personal holding company within the meaning of section 501 during those years. Held, that such failure was due to willful neglect and not to reasonable cause and that accordingly petitioner is liable for the statutory penalty for failing to file such returns.

1Opinion of the Court

Haywood Lumber and Mining Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Haywood Lumber & M. Co. v. Commissioner

Docket No. 15921

United States Tax Court

12 T.C. 735; 1949 U.S. Tax Ct. LEXIS 205;

May 11, 1949, Promulgated

Decision will be entered for respondent.

Petitioner failed to file a personal holding company surtax return in 1941 and 1942, though it was a personal holding company within the meaning of section 501 during those years. Held, that such failure was due to willful neglect and not to reasonable cause and that accordingly petitioner is liable for the statutory…

2Cases cited5 opinions

  1. Southeastern Finance Co. v. CommissionerUnited States Tax Court · 1945
  2. Tarbox Corp. v. CommissionerUnited States Tax Court · 1946
  3. Hermax Co. v. CommissionerUnited States Tax Court · 1948
  4. Haywood Lumber & M. Co. v. CommissionerUnited States Tax Court · 1949
  5. Genesee Valley Gas Co. v. CommissionerUnited States Tax Court · 1948

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