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Hermax Co. v. Commissioner of Internal Revenue.

decided: July 29, 1949.

HERMAX CO., INC., PETITIONER,
v.
COMMISSIONER OF INTERNAL REVENUE.



Before BIGGS, Chief Judge, and McLAUGHLIN and O'CONNELL, Circuit Judges.

Per Curiam.

We agree with the Tax Court that the taxpayer has not shown reasonable cause for its failure to file personal holding company returns. Cf. our decision in Hatfried, Inc. v. Commissioner of Internal Revenue, 162 F.2d 628. It follows that the taxpayer must be held liable for the statutory penalty for the years involved. Accordingly the decision of the Tax Court will be affirmed on its decision as reported in 11 T.C. 442.

19490729

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