Legal Opinion

Palmisano v. United States

District Court, E.D. Louisiana

Decided January 22, 1958No. Civ. A. 6522, 6523PublishedCited by 9 opinions

1Opinion of the Court

J. SKELLY WRIGHT, District Judge.

The single question presented by these cases is: May the penalty imposed for substantial underestimation of estimated tax be assessed against taxpayers when the penalty for failure to file a declaration of estimated tax has previously been assessed. Taxpayers here failed to file a declaration of estimated tax as required by Section 294(d)(1)(A) 1 of the Internal Revenue Code of 1939, as amended. The Commissioner assessed the penalty provided under that statute for failure to file a declaration of estimated tax, and, in addition, assessed the penalty under…

2Cases cited17 opinions

  1. Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
  2. United States v. GrimaudSupreme Court of the United States · 1911
  3. Helvering v. WinmillSupreme Court of the United States · 1938
  4. United States v. BirdsallSupreme Court of the United States · 1914
  5. Fuller v. CommissionerUnited States Tax Court · 1953

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3Cited by9 opinions

  1. Commissioner v. AckerSupreme Court of the United States · 1959
  2. Fred N. Acker v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1958
  3. J. D. Abbott and Kathryn Abbott v. Commissioner of Internal Revenue, Carl M. Wolfe and Mary E. Wolfe v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
  4. Josef C. Patchen and Aleyne E. Patchen v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1958
  5. John R. Hansen and Shirley G. Hansen v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1958

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