Tax Impacts

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.