The Tax Court denied the IRS’s motion for summary judgment for lack of jurisdiction because the taxpayer’s petition was untimely filed but dismissed the case, holding that the notice of deficiency ...

Law is rife with deadlines. Indeed, sometimes those deadlines are critical and outcome determinative. Abiding deadlines can mean the difference between having a case heard or a case dismissed, or a ...

The Tax Court recently held that it lacked jurisdiction to hear a case because the IRS failed to prove that it mailed a valid notice of deficiency to the taxpayer’s last known address. Facts: In ...