Legal Opinion

Marbut v. Commissioner

United States Tax Court

Decided June 24, 1957No. Docket No. 55655Published

Petitioners did not file a declaration of estimated tax for the taxable years 1950 and 1951. They did file joint individual income tax returns for those years on March 15, 1951, and March 17, 1952, respectively. On January 15, 1954, petitioners filed a "Consent" agreeing that the amount of "any" income tax due under "any return" for the year 1950 may be assessed at any time on or before June 30, 1955, and later, if a notice of deficiency in tax is sent before that date.

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Petitioners did not file a declaration of estimated tax for the taxable years 1950 and 1951. They did file joint individual income tax returns for those years on March 15, 1951, and March 17, 1952, respectively. On January 15, 1954, petitioners filed a "Consent" agreeing that the amount of "any" income tax due under "any return" for the year 1950 may be assessed at any time on or before June 30, 1955, and later, if a notice of deficiency in tax is sent before that date. On September 24, 1954, respondent mailed petitioners a notice of deficiencies in additions to income tax for 1950 and 1951,…

1Opinion of the Court

Harold C. Marbut and Dorothy H. Marbut, Petitioners, v. Commissioner of Internal Revenue, Respondent

Marbut v. Commissioner

Docket No. 55655

United States Tax Court

28 T.C. 687; 1957 U.S. Tax Ct. LEXIS 153;

June 24, 1957, Filed

Decision will be entered for the respondent.

Petitioners did not file a declaration of estimated tax for the taxable years 1950 and 1951. They did file joint individual income tax returns for those years on March 15, 1951, and March 17, 1952, respectively. On January 15, 1954, petitioners filed a "Consent" agreeing that the amount of "any" income tax due under "any return"…

2Cases cited18 opinions

  1. Fuller v. CommissionerUnited States Tax Court · 1953
  2. Jones v. CommissionerUnited States Tax Court · 1956
  3. Hartley v. CommissionerUnited States Tax Court · 1954
  4. Patchen v. CommissionerUnited States Tax Court · 1956
  5. Bouche v. CommissionerUnited States Tax Court · 1952

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