Court of Appeals for the Fourth Circuit January 14, 1982, 81-1231 (The Pants Rack, Inc. v. United States)

HAYNSWORTH, Senior Circuit Judge:

The question is the interpretation of 26 U.S.C.A. § 6655(d)(2) in the context of a corporation’s duty to pay in advance installments of estimated income tax liability during the first year after revocation of an' election to be taxed under Subehapter S.