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Tax Controversy Report

Filing Deadlines

Tax Court Holds BBA Partnership Petition Filing Deadline Is Not Jurisdictional

By Adam Young on August 5, 2026

In Big Apple Tompkins Realty LLC v. Commissioner, the Tax Court addressed a question of first impression: whether I.R.C. § 6234(a)’s 90-day petition filing deadline for partnerships subject to…

Continue Reading Tax Court Holds BBA Partnership Petition Filing Deadline Is Not Jurisdictional
Posted in Civil Tax, Commissioner of Internal Revenue, Federal Taxes, General Tax Controversy News & Updates, IRS Audits, IRS Chief Counsel, IRS Large Business and International (LB&I) Division, Legislation, Small Business/Self-Employed, Tax Controversy Litigation

Tax Controversy Report

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