Pleasant Valley Wine Co. v. Commissioner
United States Tax Court
Statute of Limitation -- Last Day on Saturday -- Application for Relief Under Section 722 -- Sections 722 (d), 322 (b) (1). -- An application for relief under section 722 stamped "received" by the Bureau of Internal Revenue at 12:40 p. m. on Monday, November 17, 1947, was filed too late where the three-year period provided in section 322 (b) (1) expired on November 15, 1947, a Saturday on which the Bureau of Internal Revenue was not open officially.
1Opinion of the Court
The Pleasant Valley Wine Co., Petitioner v. Commissioner of Internal Revenue, Respondent
Pleasant Valley Wine Co. v. Commissioner
Docket No. 19394
United States Tax Court
14 T.C. 519; 1950 U.S. Tax Ct. LEXIS 238;
March 31, 1950, Promulgated
Decision will be entered for the respondent.
Statute of Limitation -- Last Day on Saturday -- Application for Relief Under Section 722 -- Sections 722 (d), 322 (b) (1). -- An application for relief under section 722 stamped "received" by the Bureau of Internal Revenue at 12:40 p. m. on Monday, November 17, 1947, was filed too late where the three-year period…
2Cases cited2 opinions
- Meyer v. Hot Springs Imp. Co.Court of Appeals for the Ninth Circuit · 1909
- Pleasant Valley Wine Co. v. CommissionerUnited States Tax Court · 1950