Procedurally Taxing: Tax Court Jurisdiction When Taxpayer Late Files the Request for a Collection Due Process Hearing (March 30, 2021)

Keith Fogg, Clinical Professor of Law at Harvard Law School , discusses Ramey v Commissioner, 156 T.C. No. 1 (2021).

In Ramey v Commissioner, 156 T.C. No. 1 (2021) the Tax Court determined in a precedential opinion that when the IRS issues a notice of decision rather than a notice of determination and the taxpayer has filed the collection due process (CDP) request late, the Court lacks jurisdiction to hear the case.  The taxpayer, a lawyer, represented himself and pegged his arguments to last known address rather than jurisdiction.  Nonetheless, the decision expands the Court’s narrow view of jurisdiction to another setting without addressing the Supreme Court precedent on jurisdiction and its impact on the timing of the filing of documents.

To see the full article, click: “Tax Court Jurisdiction When Taxpayer Late Files the Request for a Collection Due Process Hearing.”

To download the full opinions, click: Ramey v Commissioner, 156 T.C. No. 1 (2021).

Posted by Bella Hoang, Managing Associate Editor, Wealth Strategies Journal.

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