Boechler v. Commissioner, 596 U.S. 199

In 2015 the IRS assessed an "intentional disregard" penalty against Boechler, P.C. and notified the firm of its intent to levy property to collect the penalty. 26 U.S.C. §§6330(a), 6721.
Boechler requested a collection due process (CDP) hearing under §6330(b); the Independent Office of Appeals sustained the proposed levy.
§6330(d)(1) gives a taxpayer 30 days to petition the Tax Court for review of a CDP determination; Boechler filed its petition one day late.
The Tax Court dismissed for lack of jurisdiction; the Eighth Circuit affirmed, holding the 30‑day deadline jurisdictional and not subject to equitable tolling.
The Supreme Court granted certiorari to decide (1) whether §6330(d)(1)’s 30‑day limit is jurisdictional and (2) whether, if nonjurisdictional, it is subject to equitable tolling.
The Court held the 30‑day deadline is nonjurisdictional and therefore subject to equitable tolling; the case was reversed and remanded for resolution of tolling on the facts.

Issue	Plaintiff's Argument (Boechler)	Defendant's Argument (Commissioner)	Held
Whether §6330(d)(1)’s 30‑day filing deadline is jurisdictional	The deadline is procedural and independent of the Tax Court’s jurisdictional grant; the phrase "such matter" does not clearly tie jurisdiction to the deadline	The phrase "such matter" (and the sentence structure) conditions Tax Court jurisdiction on timely filing, so the deadline is jurisdictional and cannot be tolled	The deadline is nonjurisdictional: the text does not clearly and plainly make the time limit jurisdictional under the clear‑statement rule
Whether the 30‑day deadline is subject to equitable tolling	Equitable tolling should apply to nonjurisdictional statutory deadlines like §6330(d)(1)	Equitable tolling is inappropriate (invokes Brockamp and administrability concerns); the IRS needs certainty to proceed with collections	The deadline is presumptively subject to equitable tolling; Brockamp is distinguishable; entitlement to tolling to be decided on remand

Henderson v. Shinseki, 562 U.S. 428 (established limits on labeling requirements "jurisdictional")
Arbaugh v. Y & H Corp., 546 U.S. 500 (requires clear congressional statement to treat procedural rule as jurisdictional)
Irwin v. Department of Veterans Affairs, 498 U.S. 89 (presumption that nonjurisdictional statutes are subject to equitable tolling)
United States v. Brockamp, 519 U.S. 347 (held equitable tolling inapplicable to a distinct tax‑refund deadline; Court distinguishes that rule here)
Sebelius v. Auburn Regional Medical Center, 568 U.S. 145 (proximity of jurisdictional text does not make a provision jurisdictional without clear tie)
United States v. Kwai Fun Wong, 575 U.S. 402 (use of traditional tools of statutory construction to identify jurisdictional rules)
Kontrick v. Ryan, 540 U.S. 443 (jurisdictional requirements define court’s adjudicatory authority)
Holland v. Florida, 560 U.S. 631 (applied equitable tolling to a statutory deadline with a single statutory exception)
Sossamon v. Texas, 563 U.S. 277 (multiple plausible interpretations undercut a claim that a requirement is clearly jurisdictional)
Weinberger v. Salfi, 422 U.S. 749 (parsing a single statutory sentence to distinguish jurisdictional from nonjurisdictional elements)