Nate Maniktala v. CIR
Split Score
What is a Split Score?
This score (0-100) indicates how likely this case is to be reviewed by the Supreme Court based on:
Case Summary
Disposition
Reversed
The Eighth Circuit held that the 90-day deadline in 26 U.S.C. § 6213(a) for filing a Tax Court petition is a non-jurisdictional claim-processing rule that can be equitably tolled. It therefore reversed the Tax Court’s dismissal of the Maniktalas’ untimely petition and remanded for the Tax Court to decide whether equitable tolling applies.
Circuit Split Identified
Legal Issue
Whether the 90-day filing deadline in 26 U.S.C. § 6213(a) is jurisdictional (thus barring untimely petitions) or a non-jurisdictional, equitably tollable claim-processing rule.
Circuit Positions
§ 6213(a) deadline is non-jurisdictional and subject to equitable tolling
§ 6213(a) deadline is jurisdictional; Tax Court lacks authority over untimely petitions
Conflict Summary
Several circuits have recently ruled that § 6213(a)’s deadline is non-jurisdictional and subject to equitable tolling, while earlier decisions in other circuits continue to treat the deadline as a strict jurisdictional bar that deprives the Tax Court of authority over late petitions.