Legal Opinion

Hotel Equities Corp. v. Commissioner

United States Tax Court

Decided December 15, 1975No. Docket No. 7538-73Published

Rule 121, Tax Court Rules of Practice and Procedure. -- On July 14, 1970, petitioner's tax return, which was due on July 15, 1970, was mailed in a properly addressed envelope, postage prepaid.

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Rule 121, Tax Court Rules of Practice and Procedure. -- On July 14, 1970, petitioner's tax return, which was due on July 15, 1970, was mailed in a properly addressed envelope, postage prepaid. The other requirements of sec. 7502, I.R.C. 1954, were met for the return to be deemed under sec. 7502 as filed on July 14, 1970. The return was stamped with respondent's stamp as received on July 17, 1970. Respondent mailed a notice of deficiency to petitioner on July 17, 1973. Held, the 3-year statute of limitations on assessments under sec. 6501, I.R.C. 1954, had expired at the time the notice of…

1Opinion of the Court

Hotel Equities Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent

Hotel Equities Corp. v. Commissioner

Docket No. 7538-73

United States Tax Court

65 T.C. 528; 1975 U.S. Tax Ct. LEXIS 13;

December 15, 1975, Filed

Rule 121, Tax Court Rules of Practice and Procedure. -- On July 14, 1970, petitioner's tax return, which was due on July 15, 1970, was mailed in a properly addressed envelope, postage prepaid. The other requirements of sec. 7502, I.R.C. 1954, were met for the return to be deemed under sec. 7502 as filed on July 14, 1970. The return was stamped with respondent's stamp as…

Also in this document: Dissent.

2Cases cited40 opinions

  1. Church of the Holy Trinity v. United StatesSupreme Court of the United States · 1892
  2. Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
  3. Atlantic Cleaners & Dyers, Inc. v. United StatesSupreme Court of the United States · 1932
  4. Helvering v. Stockholms Enskilda BankSupreme Court of the United States · 1934
  5. United States v. LombardoSupreme Court of the United States · 1916

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