Bilco Co. v. Commissioner of Revenue Services

Although tax statutes are notoriously complex, these consolidated tax cases turn on the construction of two simple statutory words: “due date.” The problem can be very briefly stated. General Statutes § 12-222 (b) provides that an annual corporation business tax return is “due on or before the first day of the fourth month next succeeding the end of the income year.” The return of a corporation operating on a calendar year basis is, for example, due on April 1. The commissioner of revenue services (commissioner) is, however, permitted to “grant a reasonable extension of time for filing a…