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April 21, 2022

Unanimous Supreme Court holds 30-day time limit for requesting CDP-determination review is subject to equitable tolling

Reversing the Eighth Circuit (and Tax Court), the U.S. Supreme Court has unanimously held in Boechler, PC v. Commissioner that the 30-day time limit under IRC Section 6330(d)(1) to petition the Tax Court to review a collection due process (CDP) determination is a nonjurisdictional deadline subject to equitable tolling. The Court remanded the question of whether, under the facts at issue, Boechler is entitled to equitable tolling.