Legal Opinion
Tilden v. Commissioner
Court of Appeals for the Seventh Circuit
Decided January 13, 2017No. 15-3838PublishedCited by 15 opinions
1Opinion of the Court
EASTERBROOK, Circuit Judge.
Taxpayers living in the United States have 90 days to file a petition asking the Tax Court to review a notice of deficiency sent by the Commissioner of Internal Revenue. 26 U.S.C. § 6213(a). Robert Tilden got such a notice covering his tax years 2005, 2010, 2011, and 2012. The last day to seek review was April 21, 2015. The Tax Court received Tilden’s petition on April 29, 2015, and dismissed it as untimely. The Commissioner has confessed error—properly so, we conclude.
Although § 6213(a) requires petitions to be filed within 90 days, another statute treats mailing…
2Cases cited13 opinions
- Irwin v. Department of Veterans AffairsSupreme Court of the United States · 1991
- Bowles v. RussellSupreme Court of the United States · 2007
- City of Kenosha v. BrunoSupreme Court of the United States · 1973
- John R. Sand & Gravel Co. v. United StatesSupreme Court of the United States · 2008
- John R. Sand & Gravel Co. v. United StatesSupreme Court of the United States · 2008
8 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Christine Dancel v. Groupon, Inc.Court of Appeals for the Seventh Circuit · 2019
- Gerald Winfield v. Stephanie DorethyCourt of Appeals for the Seventh Circuit · 2017
- Organic Cannabis Foundation v. CirCourt of Appeals for the Ninth Circuit · 2020
- Matuszak v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 2017
- Christine Dancel v. Groupon, Inc.Court of Appeals for the Seventh Circuit · 2019
10 more not listed; retrieve them via the Exa API.