Tax Court Filing Deadlines ANBLE Tax Letter

Tax Court Filing Deadlines ANBLE Tax Letter

The Complex World of Tax Deadlines Explored: Insights from The ANBLE Tax Letter

Tax Deadline

Getting the right tax advice and tips is vital in the complex tax world we live in. The ANBLE Tax Letter helps you stay right on the money with the latest news and forecasts, providing insight from our highly experienced team. Whether you’re an individual taxpayer or a business owner, understanding the nuances of tax laws can save you time, money, and potential legal headaches. With that in mind, let’s delve into one of the fascinating topics covered in our Tax Letter: U.S. tax court filing deadlines.

A Supreme Court Case Broadens the Interpretation of Filing Deadlines

“How broad is a U.S. Supreme Court case on U.S. Tax Court filing deadlines?” This intriguing question opens up a world of legal exploration. In April 2022, the Supreme Court made a groundbreaking ruling, siding with a taxpayer who filed a Tax Court petition one day late to seek a collection due process hearing. The court ruled that the statutory 30-day period for filing a petition in a collection due-process case can be waived by a court for equitable reasons.

Let’s take a closer look at the circumstances that led to this pivotal case. After a company failed to pay a penalty, the IRS sent a notice of determination sustaining a levy. Under normal circumstances, the taxpayer would have had 30 days to petition the Tax Court for a collection due process hearing, starting from the date on the letter. However, in this case, the petition was mailed on the 31st day, rendering it technically late.

The Supreme Court’s decision shook up previous rulings by both the Tax Court and an appeals court. It sent the case back down to the Tax Court to determine whether, based on the facts, it should review the IRS’s collection due process determination, despite the late filing of the petition by the taxpayer.

Late Tax Court Petitions in Deficiency Cases: An Ongoing Debate

While the Supreme Court’s ruling shed light on collection due process cases, its implications for late Tax Court petitions in deficiency cases remained an open question. In deficiency cases, taxpayers typically have 90 days from the date of an IRS deficiency notice to either pay the tax or petition the Tax Court for relief. The IRS and the Tax Court have maintained that the 90-day rule is set by statute and cannot be tolled for late petitions.

One notable case in November 2022 involved a firm that filed its petition on the 91st day, exceeding the statutory deadline. The Tax Court dismissed the case, upholding the inflexible nature of the 90-day rule in deficiency cases. According to the Tax Court’s interpretation, it lacked the authority to waive the deadline for equitable reasons. In this instance, the Tax Court’s decision highlighted the distinction between the 30-day collection due process hearing deadline and the 90-day deficiency deadline.

However, in a contrasting turn of events, the 3rd Circuit Court of Appeals took a different stance in a recent case involving a couple who claimed they never received the deficiency notice from the IRS. They filed a late Tax Court petition, which was initially dismissed by the Tax Court. The appeals court reversed the decision, drawing in part on the 2022 Supreme Court ruling. The 3rd Circuit Court of Appeals argued that the 90-day requirement for filing tax petitions in deficiency cases isn’t jurisdictional. Instead, the Tax Court must determine whether equitable tolling should be granted to the couple.

Understanding the complexities of tax law can be a daunting task. With ever-changing regulations and evolving judicial interpretations, staying informed is key to making informed tax decisions. The ANBLE Tax Letter is your trusted source for navigating the intricate world of taxes. By providing you with up-to-date information on new and pending changes in tax laws, offering tips to lower your business and personal taxes, and forecasting what the White House and Congress might do with taxes, our experienced team ensures that you stay right on the money.

While this article offers only a glimpse into the wealth of insights available in our Tax Letter, we hope it serves as an appetizer for the intriguing and informative content we provide. To get a taste of what we have to offer, we invite you to claim your free issue of The ANBLE Tax Letter or subscribe to receive our regular updates.

Remember, when it comes to taxes, knowledge truly is power. Stay informed, stay ahead, and let The ANBLE Tax Letter be your trusted guide in the world of taxes.

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