Feldman v. Commissioner
United States Tax Court
Held, Feldman Furniture Co., Inc., was not entitled to be treated as a small business corporation under subchapter S of the 1954 Code for either of its taxable years ending Sept. 30, 1961, or Sept. 30, 1962, since no valid election was filed under sec. 1372(c)(1), I.R.C. 1954, for 1961, and no election of any kind was filed for 1962.
1Opinion of the Court
OPINION
ARtjndell, Judge:
Respondent determined deficiencies in income tax for the calendar years 1958 through 1962 and an addition to the tax under section 6651(a), I.R.C. 1954, for 1961 for failure to file the 1961 return on the date prescribed therefor, in amounts as follows:
Calendar year Deficiency Addition
1958__ $4, 004, 17 _
1959_ 3, 348. 49 _
1960_ 5, 447. 18 _
1961_ 6, 002. 59 $298. 58
1962_ 484. 24 _
Respondent concedes that there is no addition to the tax due from the petitioners for the taxable year 1961, under the provisions of section 6651 (a) of the Internal Revenue Code of 1954.
The…
2Cases cited3 opinions
- Frentz v. CommissionerUnited States Tax Court · 1965
- Pestcoe v. CommissionerUnited States Tax Court · 1963
- Simons v. United StatesDistrict Court, D. Connecticut · 1962
3Cited by28 opinions
- Estate of Leonard A. Wood, Deceased, J.M. Loonan, Personal Representative v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1990
- Brutsche v. CommissionerUnited States Tax Court · 1976
- Ralph L. Brutsche and Ingrid Brutsche v. Commissioner of Internal Revenue, Ruth L. Farley v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1978
- Opine Timber Co. v. CommissionerUnited States Tax Court · 1975
- Forrester v. CommissionerUnited States Tax Court · 1968
23 more not listed; retrieve them via the Exa API.