Those words from Section 7502(a)(1) are sufficient to scuttle the petition of Laura Booth, Docket No. 20531-24, filed 10/20/25. The German postmark was late, anyway.

Although late-filed petitions are the most commonly tossed, I mention Ch J Patrick J. (“Scholar Pat”) Urda’s three-page order because of the tour d’horizon he furnishes of the CCAs take on Boechler equitable tolling in Section 6213(a) deficiencies.

“In a deficiency case our jurisdiction depends upon the issuance of a valid notice of deficiency and the timely filing of a petition. See §§ 6212 and 6213; Edwards v. Commissioner, 791 F.3d 1, 4 (D.C. Cir. 2015); Hallmark Rsch. Collective v. Commissioner, 159 T.C. 126, 130 n.4 (2022) (collecting cases); see also Sanders v. Commissioner, 161 T.C. 112, 119–20 (2023) (holding that the Court will continue treating the deficiency deadline as jurisdictional in cases appealable to jurisdictions outside the U.S. Court of Appeals for the Third Circuit). Contra Oquendo v. Commissioner, 148 F.4th 820 (6th Cir. 2025) (holding that the deficiency deadline is not jurisdictional and subject to equitable tolling); Buller v. Commissioner, No. 24-1557, 2025 WL 2348969 (2d Cir. Aug. 14, 2025) (same); Culp v. Commissioner, 75 F.4th 196 (3d Cir. 2023) (same), cert. denied, 144 S.Ct. 2685 (2024).” Order, at pp. 2-3.

Less than three (count ’em, three) weeks to go before the 11/5/25 Slaughter of the Innocents (a/k/a the examination for nonattorney applicants for admission to practice before the United States Tax Court), guys. Hasten your preparations to conclusion, and stand to!