Hartley v. Commissioner

SUPPLEMENTAL FINDINGS OP FACT AND OPINION.

Black, Judge:

The Commissioner determined that petitioners failed to file a declaration of estimated tax for 1949 and, for both that year and 1950, substantially underestimated their estimated taxes. Consequently, the Commissioner determined that for 1949 petitioners were liable for estimated tax penalties under sections 294 (d) (1) (A) 1 and 294 (d) (2)1 in the total amount of $2,328.95, and that for 1950 they were liable for the section 294 (d) (2) penalty in the amount of $3,012.54.

In our report in this case filed November 24, 1954, and appearing in…