Background
Nate and Jaya Maniktala claimed research-and-development tax credits on their joint 2018 and 2019 returns based on activities of BranchPattern, Inc., an S corporation in which Nate Maniktala was a shareholder. The IRS determined that the corporation was not entitled to the credits and mailed the Maniktalas a notice of deficiency on December 20, 2023. The notice identified March 19, 2024, as the last day to petition the Tax Court.
The Maniktalas did not receive the notice until July 9, 2024, and filed their petition ten days later—four months after the statutory deadline. The Tax Court dismissed the petition on the ground that the 90-day deadline in 26 U.S.C. § 6213(a) was jurisdictional. On appeal, the Maniktalas argued that the deadline was instead a nonjurisdictional claims-processing rule subject to equitable tolling.
The Court’s Holding
The Eighth Circuit held that § 6213(a)’s 90-day deadline is not jurisdictional. Applying the Supreme Court’s clear-statement rule, the court reasoned that the deadline tells taxpayers when they may petition but does not clearly condition the Tax Court’s authority to review deficiency petitions on timely filing. The subsection’s separate jurisdictional language expressly limits the Tax Court’s power to issue injunctions and refunds, demonstrating that Congress knew how to impose jurisdictional restrictions when it intended to do so.
The court further held that the deadline is subject to equitable tolling. Because nonjurisdictional limitations periods are presumptively tollable, and § 6213(a) neither expressly prohibits tolling nor contains the kind of detailed exceptions indicating otherwise, the presumption applied. The court did not decide whether the Maniktalas themselves qualified for tolling; it reversed the dismissal and remanded for the Tax Court to decide that question in the first instance.
Key Takeaways
- The 90-day deadline for filing a Tax Court deficiency petition under § 6213(a) is a nonjurisdictional claims-processing rule in the Eighth Circuit.
- The deadline is presumptively subject to equitable tolling, although taxpayers must establish entitlement to tolling case by case.
- The ruling displaced older Eighth Circuit precedent that had labeled the deadline jurisdictional without analyzing the issue under the Supreme Court’s modern clear-statement framework.
Why It Matters
Taxpayers in the Eighth Circuit who miss the deficiency-petition deadline are no longer automatically barred on jurisdictional grounds. They may seek equitable tolling by showing that the circumstances of their particular case justify relief.
The decision also aligns the Eighth Circuit with several other circuits applying the Supreme Court’s recent distinction between jurisdictional limits and procedural filing rules. The remand leaves unresolved whether the Maniktalas’ delayed receipt of the deficiency notice satisfies the requirements for equitable tolling.