Innocent Spouse Relief Provision • Tax Court Petition • Statutory Deadline • Jurisdiction
Rubel v. Comm’r of Internal Revenue, PICS Case No. 17-0850 (3 Cir. May 9, 2017) Schwartz, J. (11 pages).
The tax court correctly concluded that it lacked jurisdiction to consider appellant’s untimely petition, even though an IRS letter gave appellant an incorrect date, because the 90-day deadline in §6015 was jurisdictional and the tax court lacked the authority to consider untimely petitions. Affirmed.
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