Legal Opinion

Genesee Valley Gas Co. v. Commissioner

United States Tax Court

Decided August 19, 1948No. Docket No. 12874Published

Petitioner, a personal holding company within the meaning of section 501, Internal Revenue Code, failed to file a surtax return as such. Held, that such failure was due to willful neglect and not to reasonable cause and that accordingly petitioner is liable for the statutory penalty for failing to file such return.

1Opinion of the Court

Genesee Valley Gas Company, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent

Genesee Valley Gas Co. v. Commissioner

Docket No. 12874

United States Tax Court

11 T.C. 184; 1948 U.S. Tax Ct. LEXIS 104;

August 19, 1948, Promulgated

Decision will be entered under Rule 50.

Petitioner, a personal holding company within the meaning of section 501, Internal Revenue Code, failed to file a surtax return as such. Held, that such failure was due to willful neglect and not to reasonable cause and that accordingly petitioner is liable for the statutory penalty for failing to file such return.

John…

2Cases cited3 opinions

  1. P. Dougherty Co. v. CommissionerUnited States Tax Court · 1945
  2. Home Guaranty Abstract Co. v. CommissionerUnited States Tax Court · 1947
  3. Genesee Valley Gas Co. v. CommissionerUnited States Tax Court · 1948

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