Bryan Camp has published an article on the TaxProf Blog, titled “Lesson From The Tax Court: The Common Law Mailbox Rule Lives!” The article begins as follows:
The United States Postal Service (USPS) is a very large, complex organization, as detailed in this webpage. It delivers some 146 billion pieces of mail a year. It has a reputation for reliability. The reputation is so strong that Congress actually made it the foundation of §7502’s statutory mailbox rule. You know the rule: timely mailing is timely filing.
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