United States Ninth Circuit

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Duggan v. Commissioner of Internal Revenue, 15-73819

Affirming the Tax Court's dismissal of a petition for review of two Internal Revenue Service Notices of Determination for lack of jurisdiction because the petitioner mistakenly counted the first day after receipt of the IRS notices as day 'zero' for the purpose of calculating the thirty days for filing a petition for review and the failure to meet the deadline divested the Tax Court of the power to hear the case or consider the argument for equitable tolling.

Appellate Information

  • Decided
  • Published 2018/01/12




  • United States Ninth Circuit


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