Rictor v. Commissioner
United States Tax Court
1. Estimated Tax -- Additions to Tax -- Concurrent Imposition of Additions for Substantial Underestimate and Failure to File. -- Imposition of addition to tax for substantial underestimate of estimated tax (sec. 294 (d) (2), I. R. C. 1939) and addition to tax for failure to file (sec. 294 (d) (1) (A)) may be concurrently imposed.
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1. Estimated Tax -- Additions to Tax -- Concurrent Imposition of Additions for Substantial Underestimate and Failure to File. -- Imposition of addition to tax for substantial underestimate of estimated tax (sec. 294 (d) (2), I. R. C. 1939) and addition to tax for failure to file (sec. 294 (d) (1) (A)) may be concurrently imposed. G. E. Fuller, 20 T. C. 308, followed. 2. Estimated Tax -- Additions to Tax -- Base Unchanged for Net Operating Loss Carryback. -- Tax correctly shown on final return for tax year 1950 is proper base for computation of additions to tax under sections 294 (d) (1) (A)…
1Opinion of the Court
OPINION.
Murdock, Judge:
The Commissioner determined for 1950 an addition to income tax of $696.17 under section 294 (d) (2) of the Internal Revenue Code of 1939, for substantial underestimate of estimated tax and an addition of $1,044'.25 under section 294 (d) (1) (A) for failure to file declarations of estimated tax. The facts have been stipulated.
The petitioners have made no showing that their failure to file declarations of estimated tax for 1950 was due to reasonable cause and not to willful neglect. The statute contains no provision excusing an understatement on a showing of reasonable…
2Cases cited5 opinions
- Acker v. CommissionerUnited States Tax Court · 1956
- Manning v. Seeley Tube & Box Co.Supreme Court of the United States · 1950
- Fuller v. CommissionerUnited States Tax Court · 1953
- Auerbach Shoe Co. v. CommissionerUnited States Tax Court · 1953
- Petterson v. CommissionerUnited States Tax Court · 1952
3Cited by12 opinions
- Josef C. Patchen and Aleyne E. Patchen v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1958
- Delsanter v. CommissionerUnited States Tax Court · 1957
- Estate of Trompeter v. CommissionerUnited States Tax Court · 1998
- Benton v. Comm'rUnited States Tax Court · 2006
- Blanton Coal Co. v. CommissionerUnited States Tax Court · 1984
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