24, 2026), the Tax Court evaluated a case where the IRS conceded it could not rely on the statutory presumption of mailing due to an incomplete U.S. Nevertheless, the court held that the Commissioner carried his burden of proving proper mailing through cumulative, circumstantial evidence.
24, 2026), the Tax Court evaluated a case where the IRS conceded it could not rely on the statutory presumption of mailing due to an incomplete U.S.
Nevertheless, the court held that the Commissioner carried his burden of proving proper mailing through cumulative, circumstantial evidence.
Consequently, because the taxpayer filed her petition well beyond the 90-day statutory period, the Tax Court dismissed the case for lack of jurisdiction under controlling Seventh Circuit precedent.
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24, 2026), the Tax Court evaluated a case where the IRS conceded it could not rely on the statutory presumption of mailing due to an incomplete U.S. Nevertheless, the court held that the Commissioner carried his burden of proving proper mailing through cumulative, circumstantial evidence. Consequently, because the taxpayer filed her petition well beyond the 90-day statutory period, the Tax Court dismissed the case for lack of jurisdiction under controlling Seventh Circuit precedent.
24, 2026) In federal tax controversy practice, few procedural hurdles carry as much consequence as the mailing of a Statutory Notice of Deficiency (SNOD) under Internal Revenue Code (I.R.C.) § 6212 and the strict 90-day jurisdictional petition window mandated by I.R.C.
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