Wells Marine, Inc. v. Renegotiation Board
United States Tax Court
Held, sec. 7502(a), I.R.C. 1954, so-called timely mailing -- timely filing statute, is applicable to petition filed in Tax Court for redetermination of excessive profits under Renegotiation Act of 1951.
1Opinion of the Court
OPINION
Section 1218 of the Renegotiation Act of 1951, providing- for review by the Tax Court of an order of the Renegotiation Board determining an amount of excessive profits, provides that petitioner may “within ninety days (not counting Sunday or a legal holiday in the District of Columbia as the last day) after the mailing [of the notice of such order] ” file a petition with the Tax Court for a redetermination of the order of the Board. In this case petitioner had until September 10,1969, a Wednesday, to file its petition within the 90-day period.
Petitioner argues that the date of the U.S.…
2Cases cited9 opinions
- Charlson Realty Company v. The United StatesUnited States Court of Claims · 1967
- Fishman v. CommissionerUnited States Tax Court · 1969
- Irving and Helen Fishman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1970
- Central Paper Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1952
- United States v. California Eastern Line, Inc.Supreme Court of the United States · 1955
4 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Sylvan v. CommissionerUnited States Tax Court · 1975
- Stewart v. Comm'rUnited States Tax Court · 2006
- Benrey v. CommissionerUnited States Tax Court · 1986
- Estate of Wood v. CommissionerUnited States Tax Court · 1989
- Estate of Wood v. CommissionerUnited States Tax Court · 1989
5 more not listed; retrieve them via the Exa API.