Custom Component Switches, Inc., a California Corporation v. United States

In this tax refund suit, taxpayer, Custom Component Switches, Inc. (Company), appeals from a judgment for the United States. The issues presented in the district court and renewed here pertain to the imposition of penalties and interest for the asserted failure of the Company to file a timely federal income tax return for the fiscal year ending April 30, 1962.

On January 15, 1962, the Company filed a “United States Declaration of Estimated Tax for Corporations” for the taxable year ending April 30, 1962. In this declaration the Company estimated its total corporate income tax for that year to be $150,000, and stated its estimated tax due for the taxable year to be $50j000. At the time the declaration was filed, the Company paid $12,500 as its first installment. In due course the Company received a “Notice of Final Installment of Corporation Estimated Tax Due.” On or about April 15, 1962, the Company paid $37,500 on the second installment of its estimated tax.

The Company’s income tax return (Form 1120) for the fiscal year was due to be filed on or before July 15, 1962. However, on that date the Company filed Form 7004, “Application by a Corporation for Automatic Extension of…