PALM BEACH TRUST CO.
v.
COMMISSIONER OF INTERNAL REVENUE.
United States Court of Appeals District of Columbia Circuit.https://leagle.com/images/logo.png
Argued March 24, 1949.
Decided April 18, 1949.
Attorney(s) appearing for the Case
Mr. B. H. Bartholow, of New York City, for petitioner.
Mr. S. Dee Hanson, Sp. Asst. to the Atty. Gen., with whom Messrs. Ellis N. Slack and A. F. Prescott, Sp. Assts. to the Atty. Gen., of Washington, D. C., were on the brief, for respondent.
Mr. Lee Anderson Jackson, Sp. Asst. to the Atty. Gen. and Mr. Charles Oliphant, Chief Counsel, Bureau of Internal Revenue. and Mr. John M. Morawski, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., also entered appearances for respondent.
Before WILBUR K. MILLER and PRETTYMAN, Circuit Judges, and WATKINS, District Judge, sitting by designation.
United States Court of Appeals District of Columbia Circuit.
PER CURIAM.
This is a petition for review of a decision of the Tax Court of the United States.1 We think that court was right in its ruling upon petitioner's liability for the personal holding company surtax. Its decision in that respect is affirmed upon the opinion of Judge Opper. In respect to the delinquency penalty, however, we disagree. Petitioner company was originally organized prior to the imposition of the personal holding company...
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