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SOUTHEASTERN FINANCE CO. v. COMMISSIONER OF INT. REV.

No. 11504.

153 F.2d 205 (1946)

SOUTHEASTERN FINANCE CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fifth Circuit.

February 5, 1946.

Attorney(s) appearing for the Case

Douglas D. Felix, of Miami, Fla., for petitioner.

Harry Baum, Robert N. Anderson, and Melva M. Graney, Sp. Assts. to Atty. Gen., Sewall Key, Acting Asst. Atty. Gen., and J. P. Wenchel, Chief Counsel, Bur. Int. Rev., and C. E. Lowery, Sp. Atty., Bur. Int. Rev., both of Washington, D. C., for respondent.

Before SIBLEY, HOLMES, and McCORD, Circuit Judges.

McCORD, Circuit Judge.

This appeal involves delinquency penalties for taxpayer's failure to file timely personal holding company returns for the years 1940 and 1941.

The question is: Did taxpayer establish "reasonable cause" for its failure to file timely personal holding company returns within the meaning of Section 291 of the Internal Revenue Code, 26 U.S.C.A. Int. Rev.Code, § 291?

Taxpayer was a corporation organized under the Florida laws...

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