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HARTLEY v. COMMISSIONER

Docket No. 47967.

23 T.C. 564 (1954)

HARRY HARTLEY AND CAREY HARTLEY, HUSBAND AND WIFE, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 31, 1954.

SUPPLEMENTAL FINDINGS OF FACT AND OPINION.

BLACK, Judge:

The Commissioner determined that petitioners failed to file a declaration of estimated tax for 1949 and, for both that year and 1950, substantially underestimated their estimated taxes. Consequently, the Commissioner determined that for 1949 petitioners were liable for estimated tax penalties under sections 294 (d) (1) (A)1 and 294 (d) (2)1

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