Charlson Realty Company v. The United States

I agree with the commissioner (his Finding 73)1 that this petition in cold fact arrived on December 7. Arrival on or before December 6 appears to me to be to all intents not a presumption merely, but a legal fiction. We know that as a practical matter sealed envelopes deposited with the United States Post Office, duly addressed and stamped, do not in this year of grace 1967 — and did not in 1962 — arrive with any such certainty and regularity as to justify the phrase “due course of mails” as a measure of time. The date of mailing no longer warrants any presumption whatever as to date of…