Justices Say Congress Must Be Clear in Blocking Tax Relief (2)

The U.S. Supreme Court appears primed to set a high bar for when Congress wants to set mandatory deadlines for challenging agency action.

The justices Wednesday heard the latest in a long line of cases in which the court is trying to distinguish truly “jurisdictional” rules, which deprive agencies from considering claims, from the flexible “claims processing rules,” which can take into account principles of fairness. Similar cases involving other contexts federal agencies regulate in are likely to come before the justices in the future.

Here, the justices are considering a rule that gives taxpayers an opportunity to contest collection ...