Partnership Can’t Upend Tax Code to Fight Tax Court Deadline

Congress didn’t intend for equitable tolling to apply to partnerships organized under the Tax Equity and Fiscal Responsibility Act of 1982, the US Tax Court said in a precedential opinion.

The Tax Court dismissed a petition by North Wall Holdings LLC after deciding “disruptive consequences” could result if the partnership prevailed in arguing that it should be able to petition to contest an IRS determination after the legally allowed time limit.

North Wall had argued it should be allowed “equitable tolling"—that is, that it be granted an exception to the Tax Court’s typical 150-day deadline to contest a deficiency—but the ...