Legal Opinion
Hotel Equities Corporation v. Commissioner of Internal Revenue
Court of Appeals for the Seventh Circuit
Decided December 8, 1976No. 76-1584PublishedCited by 54 opinions
1Opinion of the Court
SPRECHER, Circuit Judge.
The sole issue on this appeal is whether Section 7502 of the Internal Revenue Code of 1954 1 (hereinafter referred to as the Code) defines the time when a tax return is “filed” for purposes of Section 6501(a) of the Code.
I
The pertinent facts, which are undisputed for purposes of this appeal, are briefly stated. The tax return of Hotel Equities Corporation (hereinafter referred to as the taxpayer) was due on July 15, 1970. The taxpayer properly “mailed” 2 the return to the appropriate Internal Revenue Service Center on July 14, 1970. The return was “received” by the…
2Cases cited4 opinions
- Atlantic Cleaners & Dyers, Inc. v. United StatesSupreme Court of the United States · 1932
- Hotel Equities Corp. v. CommissionerUnited States Tax Court · 1975
- Phinney v. Bank Of The Southwest National AssociationCourt of Appeals for the Fifth Circuit · 1964
- Arthur J. Brown and Frieda G. Brown v. The United StatesUnited States Court of Claims · 1968
3Cited by54 opinions
- Emmons v. CommissionerUnited States Tax Court · 1989
- Gary M. Emmons and Martha C. Emmons v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
- First Charter Financial Corp., Plaintiff-Appellee-Cross-Appellant v. United States of America, Defendant-Appellant-Cross-AppelleeCourt of Appeals for the First Circuit · 1982
- Arlie Glen Skelton, Jr. v. General Motors CorporationCourt of Appeals for the Seventh Circuit · 1981
- United States v. HillsCourt of Appeals for the Seventh Circuit · 2010
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