{ Banner }

"The Current State of Equitable Tolling in Getting Past the 90-Day Tax Court Petition Filing Deadline," The Legal Intelligencer

April 25, 2025
The Legal Intelligencer

Since 2019, a series of significant legal decisions has shifted the ground beneath one of tax litigation’s most rigid procedural rules—the 90-day deadline to file a petition with the U.S. Tax Court following a Notice of Deficiency (NOD).

In an article titled, "The Current State of Equitable Tolling in Getting Past the 90-Day Tax Court Petition Filing Deadline,” published in The Legal Intelligencer on April 25, Shareholder and Chair of the Tax Controversy Practice Philip Karter and Associate Katherine A. Wheeler explore the emerging doctrine of equitable tolling, which challenges the long-held belief that this deadline is an unbreakable jurisdictional barrier.

Subscribers can read the full article here.