Mark Allison Comments on Tax Court Extending Limitations Period
Mark D. Allison spoke with CCH's Federal Tax Weekly and offered the takeaways below concerning a recent U.S. Tax Court decision. The court decided in cases where its Clerk’s Office is inaccessible on the last date of a limitations period, the limitations period will be extended to the next day that is not a Saturday, Sunday or holiday, the Tax Court has held. For the full article, please click on the above link and go to page 7.
Excerpt taken from the article.
CCH Take Away. "The Tax Court's decision reflects a rational if not equitable outcome, even where equitable principles are not expressly available. Dismissing a petition because of the Court's self-imposed closure would have defied justice for the petitioner, and the court properly utilized the available tools in its rules to achieve the correct result," Mark Allison, member, Caplin & Drysdale, Chartered, New York, told Wolters Kluwer.
- Senior Counsel