Boechler, P.C. v. Commissioner

Holding

The 30-day deadline for petitioning the Tax Court for review of a Collection Due Process determination is a non-jurisdictional claim-processing rule subject to equitable tolling.

Facts

Boechler filed a Tax Court petition one day after the 30-day statutory deadline. The Tax Court dismissed for lack of jurisdiction.

Reasoning

Justice Barrett held that Section 6330(d)(1)'s deadline does not bear a clear jurisdictional statement and is therefore a non-jurisdictional claim-processing rule. Equitable tolling can apply in appropriate cases.