Harkins v. Commissioner
United States Tax Court
On September 16, 1953, petitioner filed a declaration of estimated tax for the taxable year 1953 in which she estimated her tax to be $ 6,666.67, which amount was not based on petitioner's 1952 income or income tax return. Eighty per cent of petitioner's tax liability for 1953 substantially exceeded the amount stated in petitioner's declaration.
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On September 16, 1953, petitioner filed a declaration of estimated tax for the taxable year 1953 in which she estimated her tax to be $ 6,666.67, which amount was not based on petitioner's 1952 income or income tax return. Eighty per cent of petitioner's tax liability for 1953 substantially exceeded the amount stated in petitioner's declaration. Respondent determined additions to tax under section 294(d)(1)(A) on the ground that petitioner had not filed a timely declaration of estimated tax. Respondent also determined additions to tax under section 294(d)(2) for substantial underestimate of…
1Opinion of the Court
OPINION.
Fisher, Judge:
Respondent determined deficiencies in income tax and additions to tax against petitioner for the taxable year 1953 as follows:
Additions to tax, I.R.C. 19S9
Year Deficiency Sec. 294(d)(1)(A) Sec. S94(d)(0)
1953. — __$1,726.48 $2,737.51 $1,425
The issues (other than those disposed of by stipulation of the parties) are whether or not respondent erred in determining additions to tax for the year 1953 under the provisions of sections 294(d) (1) (A) and 294(d) (2) of the Code of 1939.
All of the facts are stipulated and are incorporated herein by reference.
Petitioner, Eose S.…
2Cases cited1 opinion
- Commissioner v. AckerSupreme Court of the United States · 1959
3Cited by8 opinions
- Sherlock v. CommissionerUnited States Tax Court · 1960
- Zongker v. CommissionerUnited States Tax Court · 1963
- Ben Stellor and Sylvia Stellor v. United StatesUnited States Court of Claims · 1961
- Estate of Jones v. CommissionerUnited States Tax Court · 1961
- Harkins v. CommissionerUnited States Tax Court · 1959
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