...additions to a tax has been made clear by this Court in passing upon similar legislation. They are provided primarily as a safeguard for the protection...investigation and the loss resulting from the taxpayer's fraud.4' In Stockwell v. United States, 13 Wall. 531, 547, 551, the Court said of a provision which...

...a civil administrative sanction and not a punitive one, the court pointing out that it is intended primarily as a safeguard for the protection of the...and the loss resulting from the taxpayer's fraud. It seems obvious that the penalty provided for in the 1912 act is designed to insure the faithful execution...

...imposed as "personal punishment on violators." See Commissioner v. Heininger, 320 US 467. Rather they are "provided primarily as a safeguard for the protection...loss resulting from the taxpayer's fraud." Helve-ring \. Mitchell, 303 US 391. The expenses in connection with settling that liability are to be considered...

...that a fifty per cent additional tax was remedial because it was provided primarily as a safeguard for protection of the revenue and "to reimburse the Government...and the loss resulting from the taxpayer's fraud" ; but this was for expense suffered in the particular case, and in a case where the Government itself...

...has held that the purpose of the civil fraud penalty is not punishment but is primarily to safeguard the revenue and to reimburse the Government for the heavy expense of investigation and for the loss resulting from the fraud.21 Therefore, the taxpayer's right not to be subjected to double...

...has held that the purpose of the civil fraud penalty is not punishment but is primarily to safeguard the revenue and to reimburse the Government for the heavy expense of investigation and for the loss resulting from the fraud.31 Therefore, the taxpayer's right not to be subjected to double...

...addition for fraud — which is not a punishment but is remedial in nature, intending to compensate the Government for the heavy expense of investigation and the loss resulting from the fraud, Helvering v. Mitchell, 303 US 391 ; Estate of Charles Louis Reimer, 12 TC 913, affd. (CA 6)...

...(1) and 23 (a) (1) (A) of the Internal Revenue Code of 1939. In Greene Motor Co., 5 TC 314, we said: Government for the heavy expense of Investigation...taxpayer's fraud." Helvering v. Mitchell, 303 US 391. The expenses in connection with settling that liability are to be considered as "ordinary and necessary,"...

...punishment on violators." See Commissioner v. Heininget; 320 US 467. Rather they are "provided primarily aa a safeguard for the protection of the revenue and to reimburse the Government for tlie heavy expense of investigation and the loss resulting from the taxpayer's fraud." Helvcring v....

...additions to a tax has been made clear by this Court In passing upon similar legislation. They are provided primarily as a safeguard for the protection...for the heavy expense of investigation and the loss resalting from the taxpayer's fraud.* * * * • ••***• it Is provided that collection of the...