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Tax Court Rules in Hallmark Research Collective v. Commissioner

On November 29, 2022, in a unanimous 17-0 opinion in Hallmark Research Collective v. Commissioner, the US Tax Court held that the 90-day time limit is jurisdictional not subject to equitable tolling. ....

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Tax Court Holds That Deficiency Petition 90-Day Time Limit Is Jurisdictional | McDermott Will & Emery

Last summer, the Supreme Court of the United States held that the 30-day time limit to file a Collection Due Process (CDP) petition is a non-jurisdictional deadline subject to equitable. ....

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