SHEEHY, District Judge.
Plaintiff, proceeding under 28 U.S.C.A. § 1346(a) (1), brought this action to recover penalties assessed against the plaintiff by the Commissioner of Internal Revenue, hereinafter referred to as Commissioner, in connection with plaintiff's income taxes for the years 1952 and 1953.
The facts as found are as hereinafter stated.
The plaintiff did not file a declaration of estimated tax as required by the 1939 Internal Revenue...
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