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Electronically Filed Tax Court Petition Was Late Due to Time Zone Difference, R.A. Nutt, 160 TC —, No. 10, Dec. 62,205

A married couple’s petition for redetermination of an income tax deficiency was untimely where they electronically filed their petition from the central time zone but after the due date in the eastern time zone, where the Tax Court is located. Accordingly, the taxpayers’ case was dismissed for lack of jurisdiction.

The deadline for the taxpayers to file a petition in the Tax Court was July 18, 2022. The taxpayers were living in Alabama when they electronically filed their petition. At the time of filing, the Tax Court‘s electronic case management system (DAWSON) automatically applied a cover sheet to their petition. The cover sheet showed that the court electronically received the petition at 12:05 a.m. eastern time on July 19, 2022, and filed it the same day. However, when the Tax Court received the petition, it was 11:05 p.m. central time on July 18, 2022, in Alabama.

Electronically Filed Petition

The taxpayers’ petition was untimely because it was filed after the due date under Code Sec. 6213(a). Tax Court Rule 22(d) dictates that the last day of a period for electronic filing ends at 11:59 p.m. eastern time, the Tax Court’s local time zone. Further, the timely mailing rule under Code Sec. 7502(a) applies only to documents that are delivered by U.S. mail or a designated delivery service, not to an electronically filed petition.

Security Summit Urges Updating Digital Security to Prevent Identity Theft, IR-2024-306

The IRS, along with Security Summit partners, urged businesses and individual taxpayers to update their security measures and practices to protect against […]

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Security Summit Urges Updating Digital Security to Prevent Identity Theft, IR-2024-306

2024 Required Amendments List Issued, Notice 2024-82

The IRS has issued its 2024 Required Amendments List (2024 RA List) for individually designed employee retirement plans. RA Lists […]

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2024 Required Amendments List Issued, Notice 2024-82

IRS Reminds Low- and Moderate-Income Taxpayers of Saver’s Credit to Save Retirement Savings in 2025 and Future Years, IR-2024-298

The IRS reminded low- and moderate-income taxpayers to save for retirement now and possibly earn a tax credit in 2025 […]

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IRS and Security Summit Partners Warn Against Bad Tax Advice on Social Media, IR-2024-302

The IRS and Security Summit partners issued a consumer alert regarding the increasing risk of misleading tax advice on social media, which […]

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IRS and Security Summit Partners Warn Against Bad Tax Advice on Social Media, IR-2024-302

IRS and Security Summit Recommend Joining IP PIN Program, IR-2024-303

The IRS and the Security Summit partners encouraged taxpayers to join the Identity Protection Personal Identification Number (IP PIN) program at […]

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IRS and Security Summit Recommend Joining IP PIN Program, IR-2024-303

IRS Warns Taxpayers to Avoid Promoters of Fraudulent Charitable Contribution Tax Schemes, IR-2024-304

The IRS warned taxpayers to avoid promoters of fraudulent tax schemes involving donations of ownership interests in closely held businesses, […]

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IRS Warns Taxpayers to Avoid Promoters of Fraudulent Charitable Contribution Tax Schemes, IR-2024-304

FL - Seminole County local government infrastructure surtax rate continues at 1%

On November 5, 2024, voters in Seminole County approved a ballot referendum extending the expiration date of Seminole County’s 1% […]

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FL - Seminole County local government infrastructure surtax rate continues at 1%

FL - Guidance provided on temporary suspension of hillsborough county discretionary sales surtaxes

Beginning January 1, 2025, dealers should temporarily stop collecting the following Florida discretionary sales surtaxes: the Hillsborough County 0.5% indigent […]

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IRS Implements Measures to Prevent Refund Delays by Accepting Duplicate Dependent Returns with IP PIN, IR-2024-294

The IRS implemented measure to avoid refund delays and enhanced taxpayer protection by accepting e-filed tax returns with dependents already […]

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IRS Implements Measures to Prevent Refund Delays by Accepting Duplicate Dependent Returns with IP PIN, IR-2024-294

IRSAC Issues 2024 Annual Report with Key Recommendations for Tax Administration, IR-2024-293

The IRS Advisory Council (IRSAC) released its 2024 annual report, offering recommendations on emerging and ongoing tax administration issues. As a […]

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IRSAC Issues 2024 Annual Report with Key Recommendations for Tax Administration, IR-2024-293