Joyce v. Commissioner
United States Tax Court
1. 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. 2. Deductions -- Depreciation -- Partial Use of Family Car for Business Purposes. -- Deduction allowed on Court's determination of reasonable allowance for depreciation. (Cohan v. Commissioner, 39 F. 2d 540.)
1Opinion of the Court
OPINION.
Murdock, Judge:
The petitioners concede that their declarations of estimated tax should have been filed on March 15 of the year to which applicable and seek to avoid the additions imposed by section 294 (d) (1) (A) by showing reasonable cause for the late filings on December 22,1950, and January 15,1952. Counsel for the petitioners argues that Walter relied upon the advice of an accountant that he did not have to file declarations of estimated tax because the general practice of the Bureau of Internal Revenue was not to require the fifing of such returns during 1950 and 1951. The…
2Cases cited4 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Southeastern Finance Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1946
- Southeastern Finance Co. v. CommissionerUnited States Tax Court · 1945
- Tarbox Corp. v. CommissionerUnited States Tax Court · 1946
3Cited by42 opinions
- Estate of Lamberth v. CommissionerUnited States Tax Court · 1958
- Picard v. CommissionerUnited States Tax Court · 1957
- Fischer v. CommissionerUnited States Tax Court · 1955
- Marbut v. CommissionerUnited States Tax Court · 1957
- Souza v. CommissionerUnited States Tax Court · 1960
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