Case: Tax Court Affirms Jurisdictional Nature of 150-Day Deadline for Partnership Item Adjustments

The U.S. Tax Court held that the 150-day deadline to file a petition seeking readjustment of partnership items under section 6226(b) of the Internal Revenue Code is jurisdictional and not subject to equitable tolling, affirming dismissal of the petition for lack of jurisdiction. Taxpayer, a partner in a partnership, filed a petition challenging adjustments made by the IRS in a Final Partnership Administrative Adjustment (FPAA) more than 150 days after the FPAA was mailed to the tax matters partner. The court examined the text, context, and historical treatment of the TEFRA partnership audit procedures and concluded that Congress intended the ...