A recent Tax Court decision was reported that may be of interest to individuals potentially dealing with tax litigation. J. Frank Best, Certified Public Accountant and United States Tax Court Practitioner, works to stay current on all IRS decisions concerning tax litigation to ensure we are fully informed and prepared for our clients.
The United States Tax Court, in an unpublished order, dismissed for lack of jurisdiction an incarcerated individual’s petition for review of a collection due process hearing because it was untimely, finding that the IRS’s erroneous advice regarding the filing date didn’t extend the statutory deadline and the prison mailbox rule didn’t apply.
HARSH SHARMA,
Petitioner,
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent