Congressional Primacy, Equitable Tolling, and Tax Court Deficiency Litigation

To obtain prepayment judicial review of deficiencies determined by the Internal Revenue Service, a taxpayer must file a Tax Court petition within 90 days of the issuance of the notice of deficiency. It has long and universally been held that the statutory petition period is jurisdictional and is not...

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Bibliographic Details
Published inThe Tax lawyer Vol. 76; no. 3; pp. 451 - 486
Main Author Johnson, Steve R
Format Journal Article
LanguageEnglish
Published Washington American Bar Association 22.03.2023
Subjects
Case law
Federal independent agencies
Judicial reviews
Jurisdiction
Laws, regulations and rules
Legislative power
Limitation of actions (Taxation)
Litigation
Powers and duties
Prepayments
Principles
Tax collection
Tax controversies
Tax court decisions
Tax courts
Taxpayer compliance
United States > US
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Summary:To obtain prepayment judicial review of deficiencies determined by the Internal Revenue Service, a taxpayer must file a Tax Court petition within 90 days of the issuance of the notice of deficiency. It has long and universally been held that the statutory petition period is jurisdictional and is not subject to equitable tolling.
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ISSN:0040-005X
2329-6089