Detroit Automotive Products Corp. v. Commissioner of Internal Revenue

The question for decision on this tax review is whether, under section 732(a) of the Internal Revenue Code, 26 U.S.C.A., the taxpayer seasonably filed a petition with the United States Tax Court for a re-determination of its tax liability. The tax court held that petitioner had not done so.

The record shows that, in conformity with the aforementioned section, the peti-tionirig taxpayer had until July 3, 1951, within which to file its petition. The record shows further that, on June 26, 1951, the taxpayer mailed its petition at Detroit, Michigan, to the Tax Court of the United States at…