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Laurenzano v. Commissioner of Internal Revenue — 4th Cir. (Sep 16, 2026)

No. 25-2020 Argued September 16, 2026 Published September 26, 2026

Peter Laurenzano took a proposed income-tax bill to the U.S. Tax Court. His petition came after the 90-day deadline, and that court dismissed it for lack of jurisdiction without deciding the tax dispute. He now asks the Fourth Circuit to hold that the deadline does not take away the Tax Court's power to hear a late petition. He also seeks a chance to argue for equitable tolling, a narrow exception for late filings in extraordinary circumstances; whether he qualifies would be a separate question. The Commissioner says the deadline is strict and cannot be extended this way. The Supreme Court allowed equitable tolling under a different Tax Court deadline in Boechler; these judges will decide what that means for this one.

Laurenzano v. Commissioner of Internal Revenue (No. 25-2020) — U.S. Court of Appeals for the Fourth Circuit, argued September 16, 2026.

Sources
Argument audio — U.S. Court of Appeals for the Fourth Circuit (public domain, 17 U.S.C. § 105):https://www.ca4.uscourts.gov/OAarchive/mp3/25-2020-20260916.mp3
Argument listing and date — Fourth Circuit:https://www.ca4.uscourts.gov/oral-argument/oral-argument-audio-files
Tax Court dismissal and appeal — U.S. Tax Court:https://ustaxcourt.gov/files/documents/Cases-Commenced-in-the-Courts-of-Appeals-August-2025.pdf
Appellate docket and counsel — Fourth Circuit public record:https://dockets.justia.com/docket/circuit-courts/ca4/25-2020
Section 6213(a) — U.S. Code:https://uscode.house.gov/view.xhtml?edition=2023&num=0&req=granuleid%3AUSC-2023-title26-section6213
Boechler opinion — U.S. Supreme Court:https://www.supremecourt.gov/opinions/21pdf/20-1472_6j37.pdf
Taxpayer rights and deficiency deadlines — National Taxpayer Advocate:https://www.taxpayeradvocate.irs.gov/wp-content/uploads/2026/01/ARC_Publication-2104_2025_Web.pdf
Uriel Hinberg — Latham & Watkins:https://www.lw.com/en/people/uriel-hinberg
Matthew Johnshoy — U.S. Department of Justice:https://www.justice.gov/d9/2024-06/23-655_warfield-final.pdf
Taxpayer position — Law360:https://www.law360.com/tax-authority/articles/2477266/tax-bill-challenge-filing-deadline-is-flexible-4th-circ-told
Commissioner position — Law360:https://www.law360.com/tax-authority/articles/2456509/tax-court-filing-deadline-is-not-flexible-4th-circ-told

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