Harkins v. Commissioner
United States Tax Court
On September 16, 1953, petitioner filed a declaration of estimated tax for the taxable year 1953 in which she estimated her tax to be $ 6,666.67, which amount was not based on petitioner's 1952 income or income tax return. Eighty per cent of petitioner's tax liability for 1953 substantially exceeded the amount stated in petitioner's declaration.
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On September 16, 1953, petitioner filed a declaration of estimated tax for the taxable year 1953 in which she estimated her tax to be $ 6,666.67, which amount was not based on petitioner's 1952 income or income tax return. Eighty per cent of petitioner's tax liability for 1953 substantially exceeded the amount stated in petitioner's declaration. Respondent determined additions to tax under section 294(d)(1)(A) on the ground that petitioner had not filed a timely declaration of estimated tax. Respondent also determined additions to tax under section 294(d)(2) for substantial underestimate of…
1Opinion of the Court
Rose S. Harkins, Petitioner, v. Commissioner of Internal Revenue, Respondent
Harkins v. Commissioner
Docket No. 68490
United States Tax Court
33 T.C. 365; 1959 U.S. Tax Ct. LEXIS 23;
November 30, 1959, Filed
Decision will be entered under Rule 50.
On September 16, 1953, petitioner filed a declaration of estimated tax for the taxable year 1953 in which she estimated her tax to be $ 6,666.67, which amount was not based on petitioner's 1952 income or income tax return. Eighty per cent of petitioner's tax liability for 1953 substantially exceeded the amount stated in petitioner's declaration. Respondent…
2Cases cited1 opinion
- Harkins v. CommissionerUnited States Tax Court · 1959