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Filing Deadlines Tax Court Deficiency Notices

Rivkin Radler LLP

Missing the Tax Court’s 90-Day Deficiency Deadline – Now What?

Rivkin Radler LLP on

Over the years, I have observed there is only one thing that a taxpayer fears more than being notified by the IRS that their income tax return for a particular taxable year has been selected for audit, and that is being...more

Latham & Watkins LLP

Third Circuit: Tax Court Filing Deadline for Deficiency Petitions Not Jurisdictional

Latham & Watkins LLP on

The Third Circuit challenges the long-held view that the timing requirements for Tax Court review of a notice of deficiency preclude any extension or delay of the filing deadline. Culp v. Commissioner is the first case in...more

Miller Canfield

Can a Tax Court Filing Deadline be Equitably Tolled?

Miller Canfield on

All is not necessarily lost if a taxpayer files a petition after the filing deadline in United States Tax Court to contest a federal tax deficiency. A recent case ruled that the filing deadline may be suspended in appropriate...more

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