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Mailbox Rule Tax Returns

McDermott Will & Emery

Ninth Circuit Allows IRS to Overrule Common-Law Mailbox Rule

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Most tax professionals are aware of the common-law “mailbox rule,” which provides that proof of proper mailing creates a rebuttable presumption that the document was physically delivered to the addressee. Internal Revenue...more

McDermott Will & Emery

U.S. Tax Court: 90 Days Is 90 Days, Shutdown or Not

McDermott Will & Emery on

On October 1, 2013, the majority of the U.S. government shut down, including the U.S. Tax Court. Despite the shutdown, the statutory deadline for filing a petition in the Tax Court cannot be extended. Under these...more

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