2025-04-19
Continuing our series on Famous Tax Quotes (quotes from court opinions and rulings with language that is colorful or that concisely states an important tax principle), today's tax quote is from a recent case where the taxpayer’s attorney (through his staff) filed a Tax Court petition using FedEx Express Saver instead of an IRS approved delivery service, such as FedEx Priority Overnight. The petition arrived at the Tax Court one day after the 90-day deadline expired.
Courts have consistently held that failure to properly mail a petition is garden variety negligence that does not warrant equitable tolling.
Belagio Fine Jewelry, Inc. v. Commr. , 164 T.C. No. 7 (2025).
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