Commissioner of Internal Revenue v. American Ass'n of Engineers Employment, Inc

SWAIM, Circuit Judge.

This case involves a petition by the Commissioner of Internal Revenue to review a decision of the Tax Court of the United States which, approved a .determination by; the Commissioner of deficiencies totaling. $7,179.86 in the taxpayer’s income tax, declared value excess profits tax and excess profits tax for the years 1939 to 1943, both inclusive, but disapproved the 25 per cent penalty imposed by the Commissioner on' these deficiencies for failure of. the taxpayer to file returns on time without reasonable cause.

The following facts are disclosed by the stipulation of…