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Case: Court Will Consider Boechler Supreme Court Case’s Application to Equitable Tolling of Results of Equivalent Hearing (T.C.) (IRC §6330)

Nov. 23, 2022, 5:00 AM

Company (C) must file a memorandum regarding the application of Boechler, P.C. v. Commissioner, No. 20-1472, 142 S. Ct. 1493 (2022) to the facts and to address whether “determination” includes the result of an equivalent hearing when the doctrine of equitable tolling would have required C to apply the collection due process (CDP) hearing procedures for a timely administrative hearing request, the Tax Court ordered, holding the IRS’s motion to dismiss for lack of jurisdiction as to 2018 in abeyance. In 2019, the IRS issued a Notice of Federal Tax Lien (NFTL) for 2010 and 2011, and C timely ...