Boechler v. Commissioner of Internal Revenue

In this case, a North Dakota professional corporation, Boechler, P.C., received a notice of determination from the IRS following a collection due process hearing regarding a tax penalty. The taxpayer filed a petition for review in the United States Tax Court one day after the 30-day deadline set by Internal Revenue Code § 6330(d)(1). The Tax Court dismissed the petition for lack of jurisdiction, treating the deadline as a jurisdictional requirement, and the Eighth Circuit affirmed. The Supreme Court of the United States granted certiorari and unanimously reversed on April 21, 2022. Writing for the Court, Justice Brett Kavanaugh held that the 30-day filing deadline is not a jurisdictional prescription but a non-jurisdictional claim-processing rule. Because Congress did not clearly state that the deadline carried jurisdictional consequences, it is subject to equitable exceptions. The case was remanded for the Tax Court to consider whether equitable tolling applied.

The U.S. Supreme Court, in a unanimous 9-0 opinion written by Justice Kavanaugh, held that the deadline is not jurisdictional but a claim-processing rule, reversing the Eighth Circuit and remanding for further proceedings to determine if equitable tolling applies.

Whether the 30-day time limit in 26 U.S.C. § 6330(d)(1) for filing a petition with the Tax Court to review an IRS collection due process determination is a jurisdictional requirement that strictly bars late filings, or a claim-processing rule that may be subject to equitable tolling.

The decision significantly narrowed the treatment of statutory deadlines as jurisdictional, reinforcing the clear-statement rule from prior precedent. It provided a pathway for taxpayers who miss strict deadlines in collection due process cases to still seek judicial review, reducing harsh dismissals on technical grounds. The ruling was widely viewed as a victory for taxpayer access to courts and brought greater clarity to procedural interpretations under the Internal Revenue Code.