1040 Springfield Avenue Corp. v. Comm'r of Internal Revenue, 185 F.2d 406 (3d Cir. 1950). · Go Syfert
1040 Springfield Avenue Corp. v. Comm'r of Internal Revenue, 185 F.2d 406 (3d Cir. 1950). Cases Citing This Book View Copy Cite
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1040 SPRINGFIELD AVENUE CORPORATION, Petitioner,
v.
COMMISSIONER OF INTERNAL REVENUE
10199.
Court of Appeals for the Third Circuit.
Dec 13, 1950.
Published opinion
185 F.2d 406
Murry M. Weinstein, New York City, for petitioner., Fred E. Youngman, Sp. Asst, to Atty. Gen. (Theron Lamar. Caudle, Asst. Atty. Gen., Ellis N. Slack, Sp. Asst, to Atty. Gen., on the brief), for resppndent.
Biggs, Goodrich, Kalodner, Per Curiam.
Published
PER CURIAM.

In this appeal from the Tax Court the taxpayer seeks to override that court’s conclusion that the failure to file a personal holding company return for the period in question was due to wilful neglect. Our decisions in Girard Investment Co. v. Commissioner, 3 Cir., 1941, 122 F.2d 843 and Hatfried, Inc. v. Commissioner, 3 Cir., 1947, 162 F.2d 628, are relied on. But unlike the situations in those cases, there is an express finding that the petitioner did not advise its tax consultant of all the facts pertaining to the question of whether or not it was a personal holding company. This finding has adequate support in the evidence. The cases above cited are not applicable.

The decision of the Tax Court will be affirmed.