Tax Court’s Stance on Time Limit for Collection Petition Upheld

July 24, 2020, 1:46 PM

The 30-day time limit for filing a collection due process petition is jurisdictional for the U.S. Tax Court, and a law firm fighting the ruling failed to prove the time limit is unconstitutional, the Eighth Circuit held Friday.

The IRS in June 2015 sent Boechler P.C. notice of a discrepancy in tax document submissions, but never heard back from the law firm, which didn’t pay the 10% “intentional disregard penalty.” After receiving a notice of intent to levy, Boechler filed the collection due process petition one day after the 30-day deadline. The Tax Court dismissed the petition for lack of ...

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