I may be deceiving myself, and the truth may not be in me. For sure, it won’t be the first time in this my blog (and elsewhere). But a tiny inkling that not only had I got it right last week in my blogpost “‘Justified?’ – I’ll Say!” 12/5/25, but that someone actually read that blogpost arose as I skimmed Maria Gritsak, Docket No. 13840-25, filed 12/8/25.

It’s the usual months-late SND petition, where Ch J Patrick J. (“Scholar Pat”) Urda trots out the standard-issue Section 6213(a) Hallmark Rsch. Collective and Sanders boilerplate about 90 days except in 2 Cir, 3 Cir and 6 Cir.

“This Court is a court of limited jurisdiction. It may therefore exercise jurisdiction only to the extent expressly provided by statute. Breman v. Commissioner, 66 T.C. 61, 66 (1976). In a case seeking the redetermination of a deficiency, the  jurisdiction of the Court depends, in part, on the timely filing of a petition by the taxpayer. Tilden v. Commissioner, 846 F.3d 882, 886-887 (7th Cir. 2017), rev’g and remanding T.C. Memo. 2015-188; 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, 152 F.4th 84 (2d Cir. 2025) (same); Culp v. Commissioner, 75 F.4th 196 (3d Cir. 2023) (same), cert. denied, 144 S. Ct. 2685 (2024).” Order, at p. 1.

What’s missing from this picture?

If you answered Pugsley, go to the head of the class.