Federal Tax Cases To Watch In The Second Half Of 2022

In this article, Lawrence (Larry) Sannicandro provides insights to Law360 on the fallout from the U.S. Supreme Court’s decision in Boechler v. Commissioner, finding that Internal Revenue Code Section 6330(d)(1)’s 30-day deadline for filing collection due process proceedings in the U.S. Tax Court is not jurisdictional and is subject to equitable tolling. Larry highlights cases that could test the limits of Boechler, including Hallmark Research Collective v. Commissioner, which asks the Tax Court to decide whether deficiency-related procedures are also subject to equitable tolling.