Legal Opinion
In Re Fisk's Estate. Fisk v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided April 16, 1953No. 11685_1PublishedCited by 51 opinions
1Opinion of the Court
ALLEN, Circuit Judge.
The sole question presented is whether the Tax Court erred in imposing a penalty under Internal Revenue Code, Section 3612 (d) (1), 26 U.S.C.A. § 3612(d) (1), for failure to file an estate tax return within the time prescribed by law. The return was due July 21, 1947. It reached the collector’s office July 22, 1947.
Respondent stated in open court that it did not rely upon the existence of “willful neglect” under the statute. The Tax Court held that the petitioner did not show that the failure to file within the time prescribed by law was due to a “reasonable cause” and…
2Cases cited11 opinions
- Spies v. United StatesSupreme Court of the United States · 1943
- United States v. MurdockSupreme Court of the United States · 1934
- Commissioner v. Lane-Wells Co.Supreme Court of the United States · 1944
- Haywood Lumber & Mining Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1950
- Hatfried, Inc. v. Commissioner of Internal Rev.Court of Appeals for the Third Circuit · 1947
6 more not listed; retrieve them via the Exa API.
3Cited by51 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- Estate of Frank Duttenhofer, Deceased, Albert J. Uhlenbrock and William Duttenhofer, Co-Executors v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1969
- Estate of Gardner v. CommissionerUnited States Tax Court · 1984
- Duttenhofer v. CommissionerUnited States Tax Court · 1967
- Giesen v. United StatesDistrict Court, W.D. Wisconsin · 1973
46 more not listed; retrieve them via the Exa API.