MILLER v. COMMISSIONER

Docket No. 61194.

18 T.C.M. 1108 (1959)

T.C. Memo. 1959-228

Bernard Miller and Shirley B. Miller, Husband and Wife v. Commissioner.

United States Tax Court.

Filed November 30, 1959.


Attorney(s) appearing for the Case

Bernard Miller, pro se, 137 Russell Rd., West Newton, Mass. Chester M. Howe, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

OPPER, Judge:

Respondent determined deficiencies in additions to tax as follows:

                 Additions to tax — I. R. C. 1939
  Year    Sec. 294(d)(1)(A)    Sec. 294(d)(2)

  1952.............    $173.41    $115.60

The issues are (1) whether petitioners' failure to file a declaration of estimated tax was due to reasonable cause and not willful neglect; (2) whether an addition...

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