Fischer v. Commissioner
United States Tax Court
Estimated Tax -- Failure to File Declaration -- Reasonable Cause -- Sec. 294 (d) (1) (A). -- No reasonable cause having been established for failure to file declarations of estimated tax, held, Commissioner's addition to tax proper. It is no excuse that the taxpayer's principal source of income is a partnership on a calendar year basis.
1Opinion of the Court
OPINION.
Murdock, Judge:
The only witnesses in the case were Walter and Howard. Neither claimed that he relied upon the advice of any other person in reaching his decision not to file a declaration of estimated tax for 1951. Walter testified that he did not recall receiving any bulletins, information, or data from tax services during the years 1950 and 1951 on the subject of filing estimates and prepayment of taxes. He said he was under the impression that if his earnings for the year 1951 were reported by the 15th of January (apparently referring to January 1952) he would be complying with the…
2Cases cited5 opinions
- Southeastern Finance Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1946
- Bouche v. CommissionerUnited States Tax Court · 1952
- Southeastern Finance Co. v. CommissionerUnited States Tax Court · 1945
- Tarbox Corp. v. CommissionerUnited States Tax Court · 1946
- Joyce v. CommissionerUnited States Tax Court · 1955
3Cited by18 opinions
- Marbut v. CommissionerUnited States Tax Court · 1957
- Cooper v. CommissionerUnited States Tax Court · 1956
- Pinkerton v. CommissionerUnited States Tax Court · 1957
- Potter v. Comm'rUnited States Tax Court · 1956
- Potter v. CommissionerUnited States Tax Court · 1956
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