The 30-day limit under Sec. 6330(d) for petitioning the Tax Court to review an IRS determination is nonjurisdictional and can be equitably tolled, the Court holds in the case of a taxpayer whose petition was one day late.
The 30-day limit under Sec. 6330(d) for petitioning the Tax Court to review an IRS determination is nonjurisdictional and can be equitably tolled, the Court holds in the case of a taxpayer whose petition was one day late.