Government Urges Supreme Court to Protect Purpose of Tax Statute

The Supreme Court would undercut a tax code provision if it rules in line with petitioners, the government said in a Dec. 9 brief.

A key question in the case is whether a regulation related to tax code Section 7502 on timely filing replaces or merely adds to the judge-made “mailbox rule.” The mailbox rule states that proof of proper mailing means courts will presume a document was delivered on time, unless given evidence to the contrary.

In its Dec. 9 brief, the government said movie producers Howard and Karen Baldwins’ reading of Section 7502 would undercut the goals ...