For more than 85 years the Tax Court, its predecessor, the Board of Tax Appeals, and those courts of appeal that addressed the issue, held that the statute of limitations for filing a petition for redetermination was jurisdictional. When a prerequisite for a lawsuit is jurisdictional, it means that if the prerequisite has not been met, the court has no power to hear the case. It was required to dismiss the case for lack of jurisdiction.
TAXLITIGATOR - Tax Controversy (Civil & Criminal) Report 
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