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PALMISANO v. UNITED STATES

Civ. A. Nos. 6522, 6523.

159 F.Supp. 98 (1958)

Dominick PALMISANO, Plaintiff, v. UNITED STATES of America, Defendant. Salvador J. CAMPAGNA et al., Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court E. D. Louisiana, New Orleans Division.

January 22, 1958.

Attorney(s) appearing for the Case

Anzelmo, Maxwell & Thriffiley, Paul J. Thriffiley, Jr., New Orleans, La., for plaintiffs.

M. Hepburn Many, Prim B. Smith, Jr., New Orleans, La., for defendant.

J. SKELLY WRIGHT, District Judge.

The single question presented by these cases is: May the penalty imposed for substantial underestimation of estimated tax be assessed against taxpayers when the penalty for failure to file a declaration of estimated tax has previously been assessed. Taxpayers here failed to file a declaration of estimated tax as required by Section 294(d) (1) (A)1 of the Internal Revenue Code of 1939, as amended. The Commissioner...

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