"Boechler": A Day Late, But Not Necessarily a Dollar Short
May 19, 2022 | New York Law Journal
The Internal Revenue Code is filled with deadlines. One such deadline provides that taxpayers who unsuccessfully challenge IRS levies in an administrative “collection due process” hearing have 30 days to petition the United States Tax Court for relief. In my latest article for the New York Law Journal, “Boechler: A Day Late, But Not Necessarily a Dollar Short,” I discuss the Supreme Court’s recent unanimous decision holding that this deadline is not jurisdictional, and that the Tax Court can apply principles of equitable tolling in deciding whether to consider delinquent petitions. While Boechler represents a win for taxpayers, it is also a valuable reminder of the need to be mindful of filing deadlines.
"Boechler": A Day Late, But Not Necessarily a Dollar Short (pdf | 161.20 KB)