In Boechler, P.C. v. Commissioner, the Supreme Court held the 30-day time limit to file a Tax Court petition for review of a collection due process determination is not a jurisdictional requirement. In a unanimous decision, the Supreme Court reversed the Eighth Circuit and found that the Tax Court has the authority to consider a late-filed petition in a collection due process case.
Supreme Court Rules Against IRS on US Tax Court Jurisdictional Issue
