Key legal question
Whether the missed appeal deadline should be restored due to alleged reliance on outdated online publication and claimed court holidays.
Extracted holding
Restoration was denied because the taxpayer was not without fault; he relied on his own legal research despite a clear and correct appeal instruction stating a 30-day deadline.
Extracted reasoning
Restoration requires clear absence of fault. The taxpayer had no compelling reason to disregard the appeal notice, and could not rely on a non-authoritative online loose-leaf version contrary to the official publication and the correct legal remedy instruction.