A.I.M. Controls, L.L.C., et al. v. CIR, No. 11-60044 (5th Cir. 2012)
Annotate this CasePetitioners appealed the Tax Court's order dismissing their action against the Government for lack of jurisdiction. At issue on appeal was whether the Tax Court lacked jurisdiction where petitioners failed to file their petition within the Tax Equity and Fiscal Responsibility Act's (TEFRA), 26 U.S.C. 6226(a)-(b), express filing period. Because the court held that section 6226's 150-day limit was jurisdictional, the court had no authority to alter it. The plain language of the statue measured the 150-day filing period from the date the IRS mailed the final partnership administrative adjustments (FPAA) and it did not contemplate tolling. Petitioners filed the present petition 418 days after the FPAA was mailed, - over 250 days late. Therefore, the court affirmed the judgment.
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