Myers May Make It Easier To Find Equitable Relief In Tax Court

By Laura Gavioli (July 16, 2019, 4:01 PM EDT) -- When is a statutory filing deadline not a deadline? A recent decision from the U.S. Court of Appeals for the District of Columbia Circuit[1] may provide an equitable avenue for hearing of late-filed petitions in U.S. Tax Court. Specifically, the D.C. Circuit's decision in Myers v. Commissioner opens the door to taxpayer arguments for equitable tolling against the Internal Revenue Service — that is, the taxpayer may be able to argue that filing deadlines should be suspended due to the IRS' failure to advise them of any adverse action....

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