Soyka v. Comm’r of Revenue

The Commissioner of Revenue ordered Sharon Soyka to pay income taxes, penalties, and interest for the 2007 tax year. Soyka had sixty days to appeal the Commissioner's order to the tax court. Instead, Soyka filed her notice of appeal to the Commissioner, who forwarded the documents to the tax court. The tax court dismissed Soyka's appeal as untimely filed because Soyka did not file her notice of appeal until more than a month after it was due and because Soyka did not file a request seeking an extension of time. The Supreme Court affirmed the tax court's dismissal of Soyka's appeal, holding (1) Soyka's failure to file her notice of appeal before the expiration of the statutory deadline deprived the tax court of subject matter jurisdiction over the appeal; and (2) because the tax court did not receive a copy of Soyka's extension request until the statutory period had expired, Soyka was not entitled to an extension of time to file her appeal. View "Soyka v. Comm'r of Revenue" on Justia Law