According to The Tax Advisor, The Ninth Circuit Court broke with its own precedent in its recent decision to hold that “Regs. Sec. 301.7502-1(e)(2) provides the exclusive rules regarding the means of proving delivery of an original or amended tax return, so the taxpayer could not prove an amended return was timely delivered based on the common law mailbox rule.”
Beavers, Regulations take precedence over common law mailbox rule, The Tax Advisor (July 1, 2019)
