Estate of Wood v. Commissioner
United States Tax Court
P elected special use valuation on its Federal estate tax return. The return was due on Mar. 22, 1982. The envelope containing the return was properly addressed to the Internal Revenue Service office in Ogden, Utah, with postage prepaid and was postmarked by the U.S. Postal Service "March 19, 1982". P, however, did not mail the return by certified or registered mail. R claims he did not receive the return.
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P elected special use valuation on its Federal estate tax return. The return was due on Mar. 22, 1982. The envelope containing the return was properly addressed to the Internal Revenue Service office in Ogden, Utah, with postage prepaid and was postmarked by the U.S. Postal Service "March 19, 1982". P, however, did not mail the return by certified or registered mail. R claims he did not receive the return. Held, sec. 7502(a) is applicable to this case pursuant to sec. 7502(a)(2). Held, further, to show delivery, P may rely on the presumption that a properly mailed document is actually…
1Opinion of the Court
Estate of Leonard A. Wood, Deceased, J.M. Loonan, Personal Representative, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Wood v. Commissioner
Docket No. 48020-86
United States Tax Court
92 T.C. 793; 1989 U.S. Tax Ct. LEXIS 51; 92 T.C. No. 46;
April 12, 1989April 12, 1989, Filed
Decision will be entered for the petitioner.
P elected special use valuation on its Federal estate tax return. The return was due on Mar. 22, 1982. The envelope containing the return was properly addressed to the Internal Revenue Service office in Ogden, Utah, with postage prepaid and was postmarked by…
Also in this document: Concurrence.
2Cases cited33 opinions
- Hagner v. United StatesSupreme Court of the United States · 1932
- United States v. LombardoSupreme Court of the United States · 1916
- Rosenthal v. WalkerSupreme Court of the United States · 1884
- Meckel v. Continental Resources Co.Court of Appeals for the Second Circuit · 1985
- In Re the YODER COMPANY, Debtor. Mark S. BRATTON, Plaintiff-Appellant, v. the YODER COMPANY, Defendant-AppelleeCourt of Appeals for the Sixth Circuit · 1985
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