Picard v. Commissioner
United States Tax Court
1. At January 1, 1950, petitioner Andre Picard was employed by a lumber company at a fixed salary of $ 10,000 per year, and early in 1950 he became manager of the company, after which his compensation was his fixed salary of $ 10,000, plus a bonus based on the profits of the company for its fiscal year ending in 1950. He failed to make and file a declaration of estimated tax for 1950 until June 9, 1950, the reason for such failure being that he was unaware of any requirement…
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1. At January 1, 1950, petitioner Andre Picard was employed by a lumber company at a fixed salary of $ 10,000 per year, and early in 1950 he became manager of the company, after which his compensation was his fixed salary of $ 10,000, plus a bonus based on the profits of the company for its fiscal year ending in 1950. He failed to make and file a declaration of estimated tax for 1950 until June 9, 1950, the reason for such failure being that he was unaware of any requirement to file such a declaration. Held, that petitioner was required to file a declaration of estimated tax for 1950 on or…
1Opinion of the Court
OPINION.
TukneR, Judge:
The question is as to the petitioners’ liability for an addition to tax, under section 294 (d) (1) (A) of the Internal Revenue .Code of 1939,2 for failure to file a declaration of estimated tax for 1950, as required by the statute.
On brief, the petitioners’ contentions are formally divided into two parts: (1) That their failure to file a declaration of estimated tax was due to reasonable cause; and (2) that the consent, Form 872, as executed, was not a waiver of the statute of limitations on additions to tax provided in sections 294 (d) (1) (A) and 294 (d) (2) of the…
2Cases cited2 opinions
- Joyce v. CommissionerUnited States Tax Court · 1955
- Marbut v. CommissionerUnited States Tax Court · 1957
3Cited by20 opinions
- Shomaker v. CommissionerUnited States Tax Court · 1962
- Bryan v. CommissionerUnited States Tax Court · 1959
- Romer v. CommissionerUnited States Tax Court · 1957
- Souza v. CommissionerUnited States Tax Court · 1960
- Pleasanton Gravel Co. v. CommissionerUnited States Tax Court · 1985
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