Kenneth H. Ryesky (CUNY) has published Taxation Unchecked and Unbalanced: The Supreme Court’s Denial of Certiorari in Sorrentino, 41 Gonz. L. Rev. 505 (2006).  Here is the Introduction:

On October 3, 2005, the United States Supreme Court denied a writ of certiorari in Sorrentino v. United States, letting stand a divided authority among the Federal Circuits regarding the means of proving a timely postmark on a document mailed to the IRS or the Tax Court. Following a discussion of the split authority of the Circuits regarding the I.R.C. § 7502 postmark rule, this article will discuss the Sorrentino case and its broader implications in the context of the Constitutional checks and balances that ought be placed upon the taxation function by the judiciary.