Second Circuit Stands by Ruling on Time Limits in Some Tax Cases

The Second Circuit on Wednesday declined the IRS’s request to reconsider its ruling softening the deadline for taxpayers to petition the US Tax Court.

The government argued that the US Court of Appeals for the Second Circuit’s August decision in favor of taxpayers Mark Buller and Sarah Beatty turned away from a century of precedent and congressional intent in softening the deadline for taxpayers to petition the US Tax Court.

• The appeals court issued the one-line order less than a week after the government’s motion requesting rehearing and issued an amended opinion with minor changes
• IRC Section 6213(a), which ...