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IRS Chief Counsel Still Sees Main Tax Court Deadline as Strict

May 13, 2022, 9:33 PM

The IRS Office of Chief Counsel continues to view the main U.S. Tax Court deadline as strict after the Supreme Court ruled that a separate deadline is somewhat flexible, an official said.

“We are of course taking a very close look at the opinion and considering how it applies across the whole range of litigation that our office handles,” said Mark Cottrell, who heads an IRS Chief Counsel branch.

Cottrell was speaking at a conference hosted by the American Bar Association’s Tax Section about the high court’s April 21 ruling in Boechler, P.C. v. Commissioner. The court ...

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