Observation: The timely-mailing-as-timely-filing rule of Code Sec. postmark on the cover in which the document or payment is mailed is considered to be the date of delivery or date of payment. mail to the agency, officer, or office with which it is required to be filed or made, then the U.S. 7502(a)(1), if any return, claim, statement, or other document is required to be filed or any payment is required to be made within a prescribed period or on or before a prescribed date under any provision of the internal revenue laws, and after the prescribed period or date, the document or payment is delivered by U.S. 6698 against it, and so the partnership was not entitled to a refund of that penalty.īackground.
U.S., (DC CA ) 121 AFTR 2d 2018-860Ī district court has concluded that a partnership failed to sustain its burden of proof to show that it timely requested an extension of time to file and that IRS improperly assessed a failure-to-file penalty under Code Sec. Jones, Bell, Abbott, Fleming & Fitzgerald, LLP v. PARTNERSHIP FAILED TO SHOW EXTENSION REQUEST WAS TIMELY MAILED Posted by Kim Chen on June 22nd, 2018
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