Tax Impacts

A Tax Court Memorandum Opinion expressing no confidence that a “slipshod-cut-and-paste” notice of deficiency was the version of the notice actually sent to the taxpayer is the latest in a string of rebukes from the Court and Congress questioning the IRS’s ability to retain credible and complete records.

On April 21, 2022, the Supreme Court of the United States held in Boechler, P.C. v. Commissioner that the 30-day time limit under Internal Revenue Code (“I.R.C.” or “Code”) § 6330(d)(1) for a taxpayer to file a petition for a collection due process (“CDP”) hearing with the United States Tax Court is a non-jurisdictional deadline. The Supreme Court’s holding is significant because, as a non-jurisdictional deadline, I.R.C. § 6330(d)(1)’s 30-day time limit would not prohibit the Tax Court from considering an untimely filed petition when appropriate.