Legal Opinion
Duggan v. Commissioner
Court of Appeals for the Ninth Circuit
Decided January 12, 2018No. 15-73819PublishedCited by 6 opinions
1Opinion of the Court
OPINION
CHRISTEN, Circuit Judge:
I.R.C. § 6330(d)(1) gives taxpayers aggrieved by an Internal Revenue Service (IRS) determination thirty days to file a petition for review in the Tax Court. Philip Duggan mistakenly counted the first day after'the date of the IRS’s determination as day “zero,” and filed his petition for review on what was in fact the thirty-first day. The Tax Court held that Duggan’s failure to meet § 6330(d)(l)’s filing deadline deprived it of jurisdiction to hear his case. We affirm.
BACKGROUND
The IRS mailed to Duggan two Notices of Determination dated January 7, 2015, which…
2Cases cited19 opinions
- Gonzalez v. ThalerSupreme Court of the United States · 2012
- Bowles v. RussellSupreme Court of the United States · 2007
- Lamie v. United States TrusteeSupreme Court of the United States · 2004
- National Federation of Independent Business v. SebeliusSupreme Court of the United States · 2012
- United Food & Commercial Workers Union Local 751 v. Brown Group, Inc.Supreme Court of the United States · 1996
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3Cited by6 opinions
- Wilkins v. Menchaca (In Re Wilkins)United States Bankruptcy Appellate Panel for the Ninth Circuit · 2018
- Walby v. United StatesCourt of Appeals for the Federal Circuit · 2020
- Myers v. Comm'r of Internal Revenue ServiceCourt of Appeals for the D.C. Circuit · 2019
- Organic Cannabis Foundation v. CirCourt of Appeals for the Ninth Circuit · 2020
- Boechler, P.C. v. CIRCourt of Appeals for the Eighth Circuit · 2020
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