Tax Litigation IssuesJeremy H. Temkin, New York Law Journal
Innocent Spouses Falling Victim to Jurisdictional Time Bars
Tax Litigation Issues columnist Jeremy H. Temkin writes that the Second and Third Circuits have recently concluded that the 90-day deadline to challenge the denial of innocent spouse status constitutes a jurisdictional "adjudicatory rule" and that the failure to comply with that deadline will preclude judicial review.
This premium content is reserved for New York Law Journal subscribers.
Continue reading by getting started with a subscription.
Already a subscriber? Log in now