DISCLAIMER:  The following unofficial case summaries are prepared by the clerk's office
                        as a courtesy to the reader. They are not part of the opinion of the court.

192003P.pdf   07/24/2020  Boechler, P.C.  v.  CIR
   U.S. Court of Appeals Case No:  19-2003
   United States Tax Court   
   [PUBLISHED] [Erickson, Author, with Kelly and Stras, Circuit Judges] 
   Civil case - Federal Tax. The 30-day limit in 26 U.S.C. Sec. 6330(d)(1) 
   for filing a petition for review of a notice of determination is 
   jurisdictional as the section is a rare instance where Congress has 
   clearly expressed its intent to make a filing deadline jurisdictional; the 
   30-day deadline is neither arbitrary nor irrational and does not violate 
   the Fifth Amendment; the Tax Court decision dismissing the petition on the 
   ground it lacked jurisdiction because the petition was untimely is 
   affirmed. Judge Kelly, concurring in part and concurring in the judgment.