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Deficiency Notices Equitable Tolling

Miller Canfield

Can a Tax Court Filing Deadline be Equitably Tolled?

Miller Canfield on

All is not necessarily lost if a taxpayer files a petition after the filing deadline in United States Tax Court to contest a federal tax deficiency. A recent case ruled that the filing deadline may be suspended in appropriate...more

Freeman Law

Tax Court in Brief | Hallmark v. Comm’r | No Equitable Tolling of 90-Day Deadline to Petition Notice of Deficiency

Freeman Law on

Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose....more

McDermott Will & Emery

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

McDermott Will & Emery on

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....more

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