Precedent, judicial power, and the constitutionality of "no-citation" rules in the federal courts of appeals.

From: Stanford Law Review | Date: May 1, 2002| Author: Laretto, Kenneth Anthony | Copyright information

On April 13, 1996, Faye Anastasoff mailed a tax refund claim to the IRS. The deadline for the claim was April 15; Anastasoff believed that by mailing it before the deadline, the claim was valid. Ordinarily, she would have been right; the so-called "mailbox role" (1) provides that in most instances, a claim is timely upon receipt if it is postmarked by the original deadline. The IRS received Anastasoff's claim on April 16, and rejected it under an obscure exception to the mailbox ro...

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