TIMMERMAN, Chief Judge.
This is a civil action to recover taxes in the nature of penalties in the amount of $5,837.70 assessed against plaintiffs on a joint tax return for the fiscal year ending February 28, 1951. The Commissioner of Internal Revenue assessed a penalty in the sum of $3,511.70 under Section 294(d) (1) (A) of the Internal Revenue Code of 1939, as amended, 26 U.S.C.A. § 294(d) (1) (A), for failure to file a declaration of estimated tax for the year...
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