Center for Taxpayer Rights Supports More Time to File Petitions

The Ninth Circuit should join several other circuits in softening the rules on time limits for people to petition the US Tax Court, an advocate said.

The Center for Taxpayer Rights filed an amicus curiae brief to the US Court of Appeals for the Ninth Circuit saying the Tax Court’s normal time limit to file a petition should be nonjurisdictional—that it can be set aside when the taxpayer can demonstrate exceptional circumstances. That decision would allow taxpayer Jordan O’Neill to reverse a decision from the Tax Court dismissing his case.

Under IRC Section 6213(a), taxpayers normally have 90 days ...