United States Tax Court December 15, 1975, Docket No. 7538-73 (Hotel Equities Corp. v. Commissioner)

lead-opinion

OPINION

Scott, Judge:

Petitioner Hotel Equities Corp., on February 10,1975, filed a motion for summary judgment pursuant to Rule 121, Tax Court Rules of Practice and Procedure. The issue presented for decision is whether a tax return, which is timely mailed within the provisions of section 7502,1.R.C.