Maniktala v. Commissioner, – F.4th –, 2026 WL 2320396 (8th Cir. 2026)
Aug 11, 2026OUTCOME: Taxpayer victory. Holding reversed the US Tax Court and remanded for further review.
Briefed and argued a published taxpayer rights appeal before the U.S. Court of Appeals for the Eighth Circuit, securing reversal of the Tax Court’s dismissal of a deficiency petition. The Eighth Circui ... t held that the 90-day deadline under Internal Revenue Code section 6213(a) is not jurisdictional and is subject to equitable tolling, changing the law in the Eighth Circuit and expanding access to prepayment judicial review for taxpayers.
