U.S. Tax Court decision interpreting section 7508A(d)’s automatic and mandatory extension for filing a petition

KPMG report discusses the Tax Court’s decision in Abdo & Farah v. Commissioner

KPMG report discusses the Tax Court’s decision in Abdo & Farah v. Commissioner

The U.S. Tax Court held in Abdo & Farah v. Commissioner, 162 T.C. No. 7 (April 2, 2024), that the taxpayers were automatically entitled to an extension to file a petition with the court under section 7508A(d) by reason of the federal coronavirus (COVID-19) pandemic disaster declaration. In particular, the court found the regulations under section 7508A(d) to be invalid to the extent they limit non-pension related “time-sensitive acts that are postponed for the mandatory 60-day postponement period . . . [to] the acts determined to be postponed by the Secretary’s exercise of authority under section 7508A(a).” Read TaxNewsFlash

Read a May 2024 report* prepared by KPMG LLP tax professionals that discusses the Tax Court’s decision in Abdo.

* This article originally appeared in Tax Notes: Procedurally Taxing (May 15, 2024) and is provided with permission.

 

 

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