An update from time to time on various tax issues presented by Ed Zollars, CPA and designed for tax professionals. Users are cautioned to do their own independent research to verify any conclusions stated on this podcast--I do not claim to be infallible, but just to bring up issues to consider.

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The Mailbox Rule Comes Up Once Again

The Mailbox Rule Comes Up Once Again

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DATE : Sun, 20 Apr 2008 20:00:00 GMT
Entered in Database : 2008-04-20 20:00:00
length : 13235229
Link to the Show / Show Notes

The issue of whether Â7502(c) provides the exclusive means to prove timely filing of a document by a taxpayer is addressed yet again by the courts--and what the Third Circuit had to say, the IRS didn't like hearing.  In the case of Philadelphia Marine Trade Ass'n.-Int'l Longshoremen's Association Pension Fund et al. v. Commissioner, 2008 TNT 74-16 the Third Circuit held that the reports of the death of the common law mailbox rule were, in the words of Mark Twain, greatly exaggerated.  That places the Third Circuit in the same camp with the Eighth, Ninth and Tenth Circuits, and opposed to the positions of the Second and Sixth Circuits.

The materials for this podcast are located at http://www.edzollars.com/2008-04-21_Mailbox.pdf.

The podcast is sponsored by Leimberg Information Services, located on the web at http://www.leimbergservices.com.

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