Walled Off: Does North Wall Holdings Impact BBA?

As seen in Procedurally Taxing - Tax Notes Federal

In this article, the first of a two-part series, Managing Director and contributing author for Procedurally Taxing Jenni Black examines whether the Tax Court’s holding in North Wall Holdings sheds any light on whether section 6234(a), as enacted by the Bipartisan Budget Act of 2015, is jurisdictional or subject to equitable tolling.

Explore the second article of the series as Jenni argues that the Tax Court’s reasoning in North Wall Holdings as to why the filing deadline under the Tax Equity and Fiscal Responsibility Act of 1982 is jurisdictional and not subject to equitable tolling isn’t likely to apply to the filing deadline under the Bipartisan Budget Act of 2015 because of the differences between the two regimes.