Having calmed down from my rant (see my blogpost “A Rant”, 3/7/13) and refreshed by a chat with a special employee of Apple Corporation on a special day, I turn my attention to Tax Court. Today, 3/8/13, in the absence of opinions, I find a designated order by Judge James S. Halpern that follows up nicely on another recent blogpost of mine, “Inside, Outside”, 2/28/13.

This is the short but pithy tale of Mehmood H. Darjee, Docket No. 7311-11 L, filed 3/8/13. And by the “L” hangs the tale.

Meh is fighting a NOD that confirms a Notice of Intent to Levy, but he’s more than ninety days past the magic thirty-day deadline in Section 6330(d)(1).

Giving the usual “we’re a court of limited jurisdiction and the thirty-day statutory time limit is jurisidictional, and we can’t extend it”, Judge Halpern tosses Meh, but not before Meh raises the “inside, outside” defense.

I was out of the country and far away, claims Meh, when the NOD issued and even when I filed my petition, so I should get the 150-day extended care plan for furriners and overseasniks.

Nope, says Big Jim. “Unlike section 6213(a), which provides for an extended 150-day filing period to challenge a notice of deficiency addressed to a taxpayer outside the United States, section 6330(d)(1) contains no extension for taxpayers abroad. See Sarrell v. Commissioner, 117 T.C. 122, 126 (2001). The 30-day filing period applies irrespective of the taxpayer’s location.” Order, p. 2.

So, Meh, it’s neither here nor there whether you were here or there, you’ve only got thirty days. Inside, outside–it’s all the same.