Philadelphia Marine Trade Ass'n-International Longshoremen's Ass'n Pension Fund v. Commissioner

How courts have described this case

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

• holding that 26 U.S.C. § 7422(a)’s administrative exhaustion requirement “is a prerequisite to federal jurisdiction” due to 28 U.S.C. § 1346(a)(1)’s limited waiver of sovereign immunity
• noting that a taxpayer could not rely on the common law mailbox rule to prove timely filing “because it mailed the document before the deadline, but too late for that document to arrive on time in the ordinary course of post office business”
• finding no third-party standing where “the [third party] is not only willing to sue on its own behalf — it has sued”
• reversing a district court’s granting of summary judgment because the district court failed to apply the mailbox rule that created a genuine issue of material fact as to a date of receipt
• “[Section] 7502(a)(1) protects the taxpayer only where the IRS actually receives the document at some later time.”
• section 7502(a)(1) “protects the taxpayer only where the IRS actually receives the document at some later time” than the due date

Source: CourtListener parenthetical corpus (CC0).