HARTFORD-CONNECTICUT TRUST CO. v. EATON

Nos. 219, 220.

34 F.2d 128 (1929)

HARTFORD-CONNECTICUT TRUST CO. v. EATON, Collector of Internal Revenue (two cases).

Circuit Court of Appeals, Second Circuit.

June 17, 1929.


Attorney(s) appearing for the Case

E. F. Donaghue, of New York City, for appellant.

John Buckley, U. S. Atty., of Hartford, Conn. (George H. Cohen, Asst. U. S. Atty., of Hartford, Conn., and C. M. Charest and H. B. Hunt, both of Washington, D. C., of counsel), for appellee.

Before MANTON, SWAN, and AUGUSTUS N. HAND, Circuit Judges.


AUGUSTUS N. HAND, Circuit Judge (after stating the facts as above).

The imposition of penalties for failure to file income tax returns was governed at the time these tax penalties were assessed by section 3176 of the Revised Statutes, as amended by section 1317 of the Revenue Act of 1918 (26 USCA § 98), which provided in part as follows:

"* * * In case of any failure to make and file a return or list within the...

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