U.S. Court of Appeals for the First Circuit
Kyick Holdings, LLC v. Bessent
August 17, 2026
Summary
The court affirmed dismissal of Kyick Holdings’ untimely Tax Court petition, but rejected the Tax Court’s conclusion that the filing deadline deprived it of jurisdiction. The court held that the IRS used reasonable diligence by mailing the transferee-liability notice to the address on the company’s most recent federal tax return, that the filing deadline is nonjurisdictional, and that the deadline nevertheless is mandatory and cannot be equitably tolled.