Tag: Jurisdictional

Tax Code, Regulations and Guidance

Tax Court Holds That Deficiency Petition 90-Day Time Limit Is Jurisdictional

December 2, 2022

Via: JD Supra

Last summer, the Supreme Court of the United States held that the 30-day time limit to file a Collection Due Process (CDP) petition is a non-jurisdictional deadline subject to equitable tolling (Boechler, P.C. v. Commissioner). (Our prior discussion of Boechler […]