Boechler, P.C. v. Commissioner of Internal Revenue | Case No. 20-1472 | Date Argued: 1/12/2022 | Date Decided: 4/21/2022

Background: Section 6330(d)(1) of the Internal Revenue Code establishes a 30-day time limit to file a petition for review in the Tax Court of a notice of determination from the Internal Revenue Service ("IRS").

Question Presented: Whether the time limit in Section 6330(d)(1) is a jurisdictional requirement or a claim-processing rule subject to equitable tolling.

Holding: Section 6330(d)(1)’s 30-day time limit to file a petition for review of a collection due process determination is a nonjurisdictional deadline subject to equitable tolling.

Result: Judgment REVERSED and case REMANDED.

Voting Breakdown: 9-0. Justice Barrett delivered the opinion for a unanimous Court.

Link to Opinion: Here.

Oral Advocates:

For Petitioner: Melissa Arbus Sherry, Washington, D.C. For Respondent: Jonathan C. Bond, Assistant to the Solicitor General, Department of Justice, Washington, D.C.