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RUBEL v. C.I.R.

No. 16-3526.

856 F.3d 301 (2017)

Nancy M. RUBEL, a.k.a Nancy M. Zawadzki v. COMMISSIONER OF INTERNAL REVENUE Nancy M. Rubel, Appellant.

United States Court of Appeals, Third Circuit.

Opinion Filed: May 9, 2017.

Attorney(s) appearing for the Case

T. Keith Fogg , Legal Services Center of Harvard Law School, 122 Boylston Street, Jamaica Plain, MA 02130, Carlton M. Smith [ARGUED], #4AW, 255 West 23rd Street, New York, NY 10011, Counsel for Appellant.

Richard P. Caldarone [ARGUED], Gilbert S. Rothenberg , Francesca Ugolini , United States Department of Justice, Tax Division, 950 Pennsylvania Avenue, N.W., P.O. Box 502, Washington, DC 20044, Counsel for Appellee.

Before: GREENAWAY, JR., SHWARTZ, Circuit Judges, and SIMANDLE, Chief District Judge.

OPINION

Nancy Rubel appeals the United States Tax Court's dismissal of her petition for lack of jurisdiction. Because Rubel failed to file her petition by the deadline set forth in 26 U.S.C. § 6015(e)(1)(A), and because that deadline is jurisdictional, the Tax Court properly dismissed her petition, and we will...

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