Fourth Circuit: Shari Renee Lauflett v. Commissioner

Jurisdiction grant inside parentheticals in a prefatory part of the statute makes appeals time limit jurisdictional; in addition to plain language, the fact that collections actions can't be enjoined absent a timely filing, and agency can't collect until after the cutoff establish the reading.

http://www.ca4.uscourts.gov/opinions/171986.P.pdf