ZMF Law Earns Victory at Eighth Circuit in Critical Win for Taxpayers on Hotly Contested Jurisdictional Matter
HOUSTON, Aug. 17, 2026 /PRNewswire/ -- On August 11, the U.S. Court of Appeals for the Eighth Circuit ruled in favor of taxpayers represented by Zerbe, Miller, Fingeret, Frank & Jadav LLP ("ZMF Law") on a key jurisdictional issue that will now send the case back to the U.S. Tax Court for further review.
In Maniktala v. Commissioner, the Eighth Circuit found that the U.S. Tax Court's dismissal of the taxpayers' case was improper. According to the appellate court, the petition filing deadline faced by the taxpayer couple, Nate and Jaya Maniktala, was not a jurisdictional issue. In its opinion, the court remanded the case back to the lower court to revisit the issue of whether equitable tolling applies to the Maniktala's filing deadline.
The issue came to surface when the Maniktalas received a notice of deficiency from the Internal Revenue Service ("IRS") on July 9, 2024. However, the notice had allegedly been issued in December 2023, but the Maniktalas had never received the correspondence. Given the March 19, 2024, deadline to appeal the deficiency notice at the U.S. Tax Court, the taxpayers petition filed in July 2024 was four months late.
The Maniktalas' petition contesting the deficiency was dismissed by the Tax Court, which ruled that it did not have jurisdiction to review the petition because the couple had missed the 90-day filing deadline outlined in Internal Revenue Code ("IRC") Section 6213(a). On appeal at the Eighth Circuit, ZMF Law represented the Maniktalas and argued that the Section 6213(a) deadline was not jurisdictional matter and was subject to equitable tolling that would have extended the deadline at issue.
In previous decisions, the Eighth Circuit had found that the filing deadline was in fact a jurisdictional issue, and that the courts do not have jurisdiction over an untimely petition. However, drawing on recent U.S. Supreme Court decisions, the appellate court countered its own past opinions and found that the text of Section 6213(a) "does not 'clearly mandate [a] jurisdictional reading.'"
Filing deadlines are quintessential claim-processing rules, the Eight Circuit found. "Today we hold the filing deadline in § 6213(a) is no exception," Judge Kathleen Kerrigan ruled, joining multiple other circuit courts' conclusions on the same issue.
The Eighth Circuit then moved to the issue of whether the filing deadline was subject to equitable tolling. According to the appellate court, there seemed to be nothing in the text of Section 6213(a) that would rebut the presumption that equitable tolling applies to the deadline faced by the Maniktalas. However, the court remanded the issue back to the Tax Court to determine whether the taxpayer had met their burden to warrant equitable tolling to extend the time available to file their petition.
Representing the taxpayers was Jefferson Read, Senior Tax Attorney at ZMF Law. "This decision will impact taxpayers nationwide and will offer protections for them going forward," said Read. Advocacy groups, including the Center for Taxpayer Rights, filed amicus briefs on behalf of the Maniktalas in this important case.
The Eighth Circuit's decision is a significant victory for taxpayers in an area that has been hotly contested, with contradicting circuit court decisions making the issues involved ripe for Supreme Court review.
"This appellate court victory offers incredibly important protections for taxpayers," said Jeremy Fingeret, a partner at ZMF Law. "The right of taxpayers to have access to our court system was a central issue here. I'm glad to see the Eighth Circuit has taken steps to protect taxpayers' rights and ensure they can get their day in Court."
ZMF Law continues to represent the Maniktalas and will argue on their behalf at the U.S. Tax Court on the remaining equitable tolling issue.
The case is Maniktala v. Commissioner, No. 25-1366 (8th Cir. 2026).
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