Legal Opinion

Ruben v. Commissioner

United States Tax Court

Decided March 31, 1960No. Docket No. 84148PublishedCited by 159 opinions

Failure to Pay Sufficient Estimated Tax -- Sec. 6654(a) and (d)(1). -- Section 6654(a) is mandatory and the addition to tax is imposed unless one of the exceptions applies. Extenuating circumstances are irrelevant.

1Opinion of the Court

OPINION.

Murdock, Judge:

The Commissioner determined a deficiency for 1955 represented solely by an addition to tax under section 6654(a) in the amount of $1,872.32 against Barney and Birdie G. Ruben, husband and wife. The petition was filed by the executor of the estate of Barney, deceased, and Birdie. The Commissioner then moved for judgment on the ground that the petition did not state a cause of action. The petitioners filed objections and the parties were heard on the motion. The petitioners concede that all material facts are in the petition. Those facts are assumed to be true for the…

2Cited by159 opinions

  1. Grosshandler v. CommissionerUnited States Tax Court · 1980
  2. Durovic v. CommissionerUnited States Tax Court · 1970
  3. Reaver v. CommissionerUnited States Tax Court · 1964
  4. Bagur v. Comm'rUnited States Tax Court · 1976
  5. Baldwin v. CommissionerUnited States Tax Court · 1985

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