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North Wall Holdings, LLC v. Commissioner (Tax Court 2025) Jurisdictional Deadline for TEFRA Petitions Summary

North Wall Holdings v. Commissioner, No. 27773-21., 165 T.C. No. 9, 2025 BL 376369 (Oct. 21, 2025), Court Opinion

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Tax Coda
Oct 25, 2025
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The Tax Court held that the statutory deadline for filing a TEFRA partnership petition under section 6226 is jurisdictional and not subject to equitable tolling.

Holding

The court dismissed Schuler Investments, LLC’s petition as untimely, ruling that the 150-day filing period under section 6226(b) is a jurisdictional limit. The decision confirms that equi…

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