THE timely filing of a judicial case or claim is both mandatory and jurisdictional. Failure to do so will result in the claim being considered as filed out of time and the court lacking jurisdiction. For the court to have the authority to dispose of the case based on the merits, jurisdiction over the subject matter is essential. Lacking such jurisdiction, the case will be dismissed. However, it is important to note that due process of law has two aspects: substantive and procedural. To avoid violating the due process clause, both the substantive and procedural requirements must be met.

While the Supreme Court has consistently upheld that rules of procedure are meant to secure substantial justice rather than override it, the procedural requirements under the Revised Rules of the Court of Tax Appeals (RRCTA) have worked in favor of the taxpayer in a recent case decided by the Court of Tax Appeals (CTA) en banc.