Legal Opinion

Hartford-Connecticut Trust Co. v. Eaton

Court of Appeals for the Second Circuit

Decided June 17, 1929No. 219, 220PublishedCited by 8 opinions

1Opinion of the CourtAugustus N. Hand, Circuit Judge

(after stating the facts as above). The imposition of penalties for failure to file income tax returns was governed at the time these tax penalties were assessed by section 3176 of the Revised Statutes, as amended by section 1317 of the Revenue Aet of 1918 (26 USCA § 98), which provided in part as follows:

“ * • • jn case 0£ any faiiure to make and file a return or list within the time prescribed by law, or prescribed by .the Commissioner of Internal Revenue or the collector in pursuance of law, the Commissioner of Internal Revenue shall add to the tax 25 per centum of its amount, except that…

2Cases cited2 opinions

  1. Gould v. GouldSupreme Court of the United States · 1917
  2. Dayton Bronze Bearing Co. v. GilliganCourt of Appeals for the Sixth Circuit · 1922

3Cited by8 opinions

  1. Paymer v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1945
  2. Girard Inv. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1941
  3. O'Sullivan Rubber Co. v. Commissioner of Int. Rev.Court of Appeals for the Second Circuit · 1941
  4. F. E. McGillick Co. v. CommissionerUnited States Tax Court · 1958
  5. Commissioner of Internal Revenue v. Roosevelt & Son Inv. FundCourt of Appeals for the Second Circuit · 1937

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