This jurisdictional grant is not unqualified, however, and must be read to incorporate the requirements of 19 U.S.C. § 1514. Juice Farms, Inc. v. United States, 68 F.3d 1344, 1345 (Fed. Cir. 1995). Section 1514(a) provides that "decisions of the Customs Service, including the legality of all orders and findings entering into the same, as to . . . the liquidation or reliquidation of an entry . . . shall be final and conclusive upon all persons (including the United States and any officer thereof) unless a protest is filed in accordance with this section.

In the event of late-filed submissions, equitable tolling is available only when the lateness is attributable, at least in part, to misleading governmental action. See Bailey, 160 F.3d at 1365 (noting that if the government misled the claimant into missing the filing deadline, such inducement by a government adversary may allow equitable tolling of the limitations period even absent trickery or governmental misconduct); see also Juice Farms, Inc. v. United States, 68 F.3d 1344, 1346 (Fed. Cir. 1995) (noting that equitable tolling would be allowed if the government tricked the plaintiff into missing the filing deadline). The requirements for equitable estoppel are even more stringent; equitable estoppel requires affirmative governmental misconduct.

Equitable tolling is available in suits only where notice is insufficient or "where the claimant has actively pursued his judicial remedies by filing a defective pleading [during the statutory period] or where he has been induced or tricked by his adversary's misconduct into allowing the filing deadline to pass." Irwin v. Dep't of Veteran Affairs, 498 U.S. 89, 90 (1990); See also Juice Farms, Inc. v. United States, 68 F.3d 1344, 1346 (Fed. Cir. 1995). In the present case, petitioners did not argue before the district court that a defective pleading was filed or that the IRS somehow tricked or induced petitioners into missing the filing deadline.