Commissioner v. Acker - 361 U.S. 87 (1959)

U.S. Supreme Court

Commissioner v. Acker, 361 U.S. 87 (1959)

Commissioner of Internal Revenue v. Acker

No. 13

Argued October 19, 1959

Decided November 16, 1959

361 U.S. 87

Syllabus

Under the Internal Revenue Code of 1939, the failure of a taxpayer, without reasonable cause, to file a declaration of estimated income tax, as required by § 58, subjects him to the addition to the tax prescribed by § 294(d)(1)(A) for failure to file the declaration, but it does not subject him also to the addition to the tax prescribed by § 294(d)(2) for the filing of a "substantial underestimate" of his tax. Pp. 361 U. S. 87-94.

258 F.2d 568 affirmed.