Friday, October 1, 2021
The Supreme Court yesterday granted certiorari to resolve a circuit split over whether I.R.C. § 6330(d)(1)'s requirement that a petition for Tax Court review of an IRS notice of determination must be filed within 30 days is a jurisdictional requirement or a claim processing rule subject to equitable tolling. Boechler, P.C. v. Commissioner, No-18578 (Order of Dismissal Feb. 15, 2019), aff'd, 967 F.3d 760 (8th Cir. 2020).