Hatfried, Inc. v. Commissioner of Internal Rev.

The dissent in this case is upon a narrow point, but one which seems to the writer so important that the dissent should be recorded. There is full agreement in the majority’s conclusion that the taxpayer is a personal holding company. There is also agreement with the proposition that the taxpayer who presents his facts to a lawyer or certified public accountant and relies on the advice given him by either one of these persons has proved that he has acted with reasonable cause and has negatived the. charge of .wilful neglect. An analogy in the law of malicious prosecution at once suggests…