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SIMONE CORPORATION v. COMMISSIONER

Docket No. 20230.

10 T.C.M. 110 (1951)

Simone Corporation v. Commissioner.

United States Tax Court.

Entered January 25, 1951.

Attorney(s) appearing for the Case

Murray M. Weinstein, Esq., 60 Park Pl., Newark 2, N. J., for the petitioner. John E. Mahoney, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

OPPER, Judge:

By this proceeding petitioner challenges respondent's determination of a penalty of $1,389.83 for failure to file a timely personal holding company return for the taxable year September 6, 1944, to August 31, 1945. Petitioner concedes liability for the deficiency in tax, but contends its failure to file the return was due to reasonable cause and not to wilful...

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