Document Type
Article
Publication Date
6-15-2009
Publication Title
State Tax Notes
Publication Title (Abbreviation)
St. Tax Notes
Volume
52
First Page
917
Last Page
920
Abstract
Tax statutes, like statutes of all kinds, frequently prescribe dates or times by which actions are to be taken. If the actor – either the taxpayer or the state or local revenue authority – fails to act by the specified date or time, the actor sometimes can be rescued by any of several legal and equitable mechanisms.
This installment of Interpretation Matters addresses one of those mechanisms: the doctrine of equitable tolling. Part I below describes the doctrine generally and gives examples of successful use of the doctrine by taxpayers and by revenue authorities. Part II identifies possible barriers to application of the doctrine. Part III offers practice suggestions for advancing and opposing equitable tolling arguments.
Rights
© 2009 Steve R. Johnson
Faculty Biography
http://www.law.fsu.edu/our-faculty/profiles/johnson
Recommended Citation
Steve R. Johnson,
Equitable Tolling in State and Local Tax Cases, 52
St. Tax Notes
917
(2009),
Available at: https://ir.law.fsu.edu/articles/306
Comments
First published in State Tax Notes.