Jeremy Temkin 'Boechler': A Day Late, But Not Necessarily a Dollar Short
Last month, In 'Boechler, P.C. v. Commissioner of Internal Revenue', the U.S. Supreme Court unanimously held that a 30-day deadline for filing a petition is not jurisdictional and that the Tax Court can apply principles of equitable tolling in deciding to hear delinquent petitions. In this edition of his Tax Litigation Issues column, Jeremy H. Temkin examines the opinion and considers its implications.
May 18, 2022 at 12:15 PM
9 minute read
The Internal Revenue Code is filled with deadlines. Taxpayers seeking to challenge some action by the IRS in the U.S. Tax Court must be especially wary of such time limits. By statute, a taxpayer challenging an IRS levy on property is entitled to a "collection due process" hearing before the IRS's Independent Office of Appeals. If a taxpayer loses in that forum, she may seek relief by filing a petition in Tax Court within 30 days of the date of the administrative determination.
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