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Showing posts with label Statute of Limitations - Equitable Tolling. Show all posts
Showing posts with label Statute of Limitations - Equitable Tolling. Show all posts
Saturday, October 25, 2025

Tax Court in Reviewed Opinion Holds TEFRA Litigation Time Limits Jurisdictional (10/25/25)

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I am late to post on North Wall Holdings, LLC v. Commissioner , 165 T.C. ___, No. 9 (10/21/25) (reviewed opinion, T.C. Case No. 27773-21, he...
Monday, August 25, 2025

6th Circuit Joins 2nd and 3rd Circuits in Holding § 6213(a)’s 90--day Petition-Filing Deadline is Not Jurisdictional (8/25/25; 11/28/25)

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In Oquendo v. Commissioner , ___ F.4th ___ (6th Cir. 8/25/25) (CA6 here , TN here , and GS here ), the panel held unanimously that § 6213(a)...
Thursday, August 14, 2025

Second Circuit Allows Possible Equitable Tolling for 90-day Petition for Redetermination of Deficiency (8/14/25; 11/28/25)

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Tax procedure enthusiasts already know that, starting with Boechler P.C. v. Commissioner , 596 U. S. 199 (2022), courts have steadily eroded...
Tuesday, December 13, 2022

Tax Court Holds that § 6213(a) Time Deadline for Petitions for Redetermination Is Jurisdictional, Thus Not Subject to Equitable Relief (12/13/22)

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I have not yet written on Hallmark Research Collective v. Commissioner , 159 T.C. 126 (2022)  (unanimous reviewed opinion), TCPamphlet  here...
Thursday, July 4, 2019

D.C. Circuit Holds Equitable Tolling May Apply to Time Limit in Whistleblower Case (7/4/19)

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In Myers v. Commissioner , ___ F.3d ___, 2019 U.S. App. LEXIS 19757 (D.C. Cir. 2019), here , the Court applied the jurisdictional/nonjurisdi...