Whether the Ninth Circuit incorrectly held that under 26 CFR §301.7502-1(e) the common-law mailbox rule no longer is available to establish timely filing of tax documents

question presented for review is: 1. Whether the Ninth Circuit incorrectly held, in conflict with precedents in the Third, Eighth, Ninth, and Tenth Circuits, that under 26 CFR §301.75021(e) the common-law mailbox rule no longer is available to establish timely filing of tax documents. ll QUESTIONS PRESENTED — Continued Additionally, in their collections due process case below, Petitioners demonstrated for the Tax Court that Respondent committed a fraud upon that court when, among other things, he filed, in response to a court order, perjured declarations and fabricated government documents. For that reason, Petitioners alternatively urged the Court of Appeals to declare the decision of the Tax Court void. However, the Court of Appeals did not address the question. The second question presented for review is: 2. Did the Court of Appeals have jurisdiction to determine whether the Tax Court decision below was void because it was obtained by fraud on the court? iii RELATED CASES ¢ Waltner v. Commissioner, No. 8726-11L, United States Tax Court. Decision entered January 21, 2016. « Waltner v. Commissioner, No. 16-72754, U.S. Court of Appeals for the Ninth Circuit. Opinion entered April 30, 2019.