Legal Opinion

Gordon R. Coates and Thelma B. Coates v. Commissioner of Internal Revenue

Court of Appeals for the Eighth Circuit

Decided June 19, 1956No. 15516_1PublishedCited by 44 opinions

1Opinion of the Court

SANBORN, Circuit Judge.

This is a petition to review a decision of the Tax Court determining that petitioners were liable for a tax of $2,462.25 under Section 294(d)(1)(A) of the Internal Revenue Code of 1939, 26 U.S.C. 1946 ed., § 294(d)(1)(A), which requires a percentage addition to a tax “In the case of a failure to make and file a declaration of estimated tax within the time prescribed [see 26 U.S.C.1946 ed. § 58], unless such failure is shown to the satisfaction of the Commissioner to be due to reasonable cause and not to willful neglect”.

The petitioners did not file a timely declaration…

2Cases cited8 opinions

  1. Cleo Syrup Corporation v. Coca-Cola Co.Court of Appeals for the Eighth Circuit · 1943
  2. Haywood Lumber & Mining Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1950
  3. Pendergrass v. New York Life Ins. Co.Court of Appeals for the Eighth Circuit · 1950
  4. Stone v. CommissionerUnited States Tax Court · 1954
  5. Pittsburgh Plate Glass Co. v. National Labor Relations BoardCourt of Appeals for the Eighth Circuit · 1940

3 more not listed; retrieve them via the Exa API.

3Cited by44 opinions

  1. United States v. BoyleSupreme Court of the United States · 1985
  2. Crocker v. CommissionerUnited States Tax Court · 1989
  3. Walter H. Kaltreider and Irene C. Kaltreider v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
  4. Shomaker v. CommissionerUnited States Tax Court · 1962
  5. Stevens Bros. Foundation, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963

39 more not listed; retrieve them via the Exa API.

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