Local Lodge No. 875, Brotherhood Railway Carmen of the United States & Canada v. Donovan

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• “The general rule is that the tax document in question is considered filed when it is delivered to the IRS. The Internal Revenue Code requires actual receipt or payment.”
• “Strong evidence of mailing will, in most cases, require more than statements by the taxpayer but rather independent evidence. The requirement of strong or independently verifiable evidence of mailing is necessary in order to avoid taxpayer fraud.”
• to be entitled to discovery, taxpayer relying on common-law mailbox rale was obliged to “produce a prima facie case for the common law mailing presumption and some evidence to question the presumption of correctness of the government’s records”

Source: CourtListener parenthetical corpus (CC0).