Charles E. Pearsall & Son v. Commissioner
United States Board of Tax Appeals
DELINQUENCY PENALTIES - REVENUE ACT OF 1926, SECTION 1103; REVENUE ACT OF 1928, SECTION 291. - "Reasonable cause" means such a cause as would prompt an ordinarily intelligent man to act under similar circumstances as did the taxpayer, in tardily filing his income tax returns. Held, upon the facts, the delinquency penalties were properly imposed.
1Opinion of the Court
opinion.
Leech :
Petitioner is a New York corporation now in dissolution. The petition herein was filed through Mabel E. Pearsall and Arthur R. Pearsall, its trustees in dissolution. Chapter 787 of the 1923 Corporation Law of New York State provides that a corporation in dissolution shall remain in existence for the purpose of suing and being sued in winding up its affairs. Its directors are trustees in charge of its liquidation.
Deficiencies were determined for years and in amounts as follows.
1925-$962.92
1926- 56. 52
1027- 44. 32
1928- 94.85
These deficiencies in tax the respondent has increased…
2Cases cited2 opinions
- Hornsby v. CommissionerUnited States Board of Tax Appeals · 1932
- Smith v. PowersDistrict Court, N.D. New York · 1919
3Cited by21 opinions
- Electric & Neon, Inc. v. CommissionerUnited States Tax Court · 1971
- Stevens Bros. Foundation, Inc. v. CommissionerUnited States Tax Court · 1962
- Mitchell v. CommissionerUnited States Tax Court · 1969
- Jockey Club v. CommissionerUnited States Board of Tax Appeals · 1934
- Vocelle v. CommissionerUnited States Tax Court · 1968
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