Tax Court Deadline Battles Have Filers Navigating a Legal Morass

A battle over whether taxpayers can file a late petition to fight a bill from the IRS is pitting demands for fair hearings against the US Tax Court’s ability to manage a torrent of fact-intensive lawsuits.

Several pending cases before federal appeals courts are challenging the Tax Court’s 90-day deadline to file tax deficiency challenges, the vast majority of cases brought there. Many of the hundreds of such cases filed every week are eventually dismissed for being late, and even more taxpayers never file in the first place for that reason.

In addition to fairness, challengers point out that the ...