The pattern continues. Petitioners who miss the 90-day cutoff for Tax Court relief in jurisdictions where Culp and its progeny has reduced the 90-day cutoff to a claim processing statute founder on failure to plead equitable tolling. Here is Judge Cathy (“NCY = No Cognomen Yet”) Yung sending off Hassan A. Daramy, Docket No. 2070-24, filed 1/9/26 for failing to state a claim upon which relief can be granted.

“Petitioner has not claimed, much less established, that equitable tolling extended that period for timely filing to the date that the Petition was filed.” Order, at p. 1.

Culp pointed out that the “United States Tax Court, Congressional Budget Justification, Fiscal Year 2024, at 23 (Feb. 1, 2023) (explaining that in Fiscal Year 2022 80% of the Tax Court petitions were filed by taxpayers proceeding pro se).” Culp, at p. 15. 

How a self-represented petitioner is to know how to plead equitable tolling is nowhere explained.