Don’t wait till the last minute. Minutes matter. The United States Tax Court recently ruled1 that electronically filed documents are considered filed when received. That timeliness is determined by reference to the eastern time zone in the District of Columbia where the Court is located, not the taxpayers’ location/local time zone. As a result, a deficiency petition taxpayers filed on the last day of the filing period at 11:05 pm central standard time was considered filed at 12:05 am eastern standard time (the next day). As a result, the filing was considered untimely and was dismissed for lack of jurisdiction.
The Court noted the provisions of IRC Section 7502 (which consider documents filed timely if mailed but not received before the deadline) were available only for physically mailed documents, not e-filed documents. The Court noted that both Tax Court Rule 22(d) and the Court’s website instructions set out 11:59 pm eastern standard time as the deadline for e-filing. So, although it was still the last day to file when measured by taxpayers’ physical locale/time zone, the relevant location/time zone for determining whether the filing deadline was met was the District of Columbia, eastern time zone, and the taxpayers did not meet this deadline.
If you want assistance with any federal income tax matter, please call one of our tax and business attorneys at 937-223-1130 or JSenney@pselaw.com.
1Sanders 160 TC 16 (6/20/2023)
