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Sonya C. Bishop

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Articles by Sonya C. Bishop

United States: First Circuit Clarifies Tax Court Filing Deadlines

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By Vivek Patel, Sonya C. Bishop
| Connect on Tech
Skip to content In brief The US Court of Appeals for the First Circuit in Kyick Holdings, LLC v. Commissioner, 188 F.4th 39 (1st Cir. 2026)affirmed the dismissal of Kyick Holdings, LLC’s untimely Tax Court petition to contest a notice of transferee liability, but rejected the Tax Court’s conclusion that the 90-day deadline in section 6213(a) is jurisdictional. The First Circuit held that the deadline is a nonjurisdictional claim-processing rule, yet is mandatory and cannot be equitably tolled.
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United States: Section 7508A(d) suspends timeframe for filing tax court petitions for certain disaster declarations

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By Sonya C. Bishop, Marc M. Levey, Vivek Patel, Alisa Simons
| Lexology Verified
On 2 April 2024, the US Tax Court held in Abdo v. Commissioner, 162 T.C. No. 7 (2024), held that the COVID-19 pandemic entitled the taxpayers to an additional 60 days to file their Tax Court petition to redetermine a deficiency. In a court reviewed opinion, the Tax Court had its first opportunity to rule on section 7508A(d), which suspends the running of the period within which a Tax Court petition must be filed due to the declaration of a national disaster.
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United States: Third Circuit holds Tax Court's 90-day petition deadline is not jurisdictional

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By Marc M. Levey, Sonya C. Bishop
| Lexology Verified
In brief In Culp v. Commissioner, the Third Circuit recently held that section 6213(a)'s 90-day period for filing a Tax Court petition for redetermination of a deficiency is not jurisdictional and is subject to equitable tolling. Relaxing strict compliance with the often draconian filing rule would allow taxpayers to have their day in court even if they fail to meet the 90-day deadline.
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