Commissioner v. Acker

-Mr. Justice Whittaker

delivered the opinion óf the Court.

This, case presents the question whether, under the Internal Revenue Code of 1939, the failure of a taxpayer to file a declaration of estimated income tax, as required by § 58,1 not only subjects him to the addition to the tax *88prescribed by § 294 (d) (1) (A) for failure to file the declaration, but also subjects bim to the further addition to the tax prescribed by § 294 (d) (2) for the filing of a “substantial underestimate’-’ of his tax.

Section 294 (d)(1)(A)' provides, in substance, ■ that if a taxpayer fails to make and. file “a…