Case Explained: Nate Maniktala; Jaya Maniktala v. Commissioner of Internal Revenue —————————— Center for Taxpayer Rights Amicus

Court: United States Court of Appeals for the Eighth Circuit Filed: 2026-08-11 The eighth-circuit held that the 90-day filing deadline in 26 U.S.C. § 6213(a) for petitioning the Tax Court to redetermine a tax deficiency is a nonjurisdictional claim-processing rule rather than a jurisdictional bar, and is therefore subject to equitable tolling. The court applied the “clear statement” rule derived from recent Supreme Court precedent, specifically *Boechler, P.C. v. Comm’r*, 596 U.S. 199 (2022), which requires Congress to clearly state that a procedural time bar limits a court’s authority to be considered jurisdictional. The court found that the statutory text of § 6213(a) fails this test because the filing deadline is directed at the taxpayer (“the taxpayer may file”), while the explicit limitation on the Tax Court’s jurisdiction appears later in the statute and applies only to specific actions like enjoining proceedings or ordering refunds, not to the court’s general authority to hear a petition. Consequently, the court rejected the Commissioner’s arguments that interpreting the deadline as nonjurisdictional would create harsh consequences under 26 U.S.C. § 7459(d) or that historical context implied a jurisdictional grant, noting that such interpretations do not satisfy the clear statement requirement. Because the deadline is nonjurisdictional, the court further held that it is presumptively subject to equitable tolling. The court found no affirmative indication in the text of § 6213(a) rebutting this presumption, distinguishing the statute from highly technical provisions like those in *United States v. Brockamp* that explicitly limit exceptions. As a result, the Eighth Circuit reversed the Tax Court’s dismissal of the Maniktalas’ petition for lack of jurisdiction and remanded the case to the Tax Court to determine in the first instance whether the taxpayers have met their burden to warrant equitable tolling based on the specific facts of their delay. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.