US Tax Court

The U.S. Tax Court is not a court of general jurisdiction. Its power and authority is limited exclusively to tax cases.

So when would You use the U.S. Tax Court?

For example, if the IRS mailed you a Notice of Deficiency, commonly referred to as “the 90-day notice,” you may consider filing a petition. This Notice is the IRS’s final administrative action indicating it intends to alter your tax liability by disallowing deductions or adding unreported income. This Notice is also issued when you have not filed a tax return and the IRS has prepared a Substitute For Return (SFR) for you.

Or, if you do not agree with an IRS Audit or Appeal determination, you may consider filing a petition.

By filing a U.S. Tax Court petition, you can:

  • Immediately stop the IRS from assessing their intended taxes, interest and penalties, in the case of a Notice of Deficiency
  • Immediately stop the IRS from making changes to your return based on the Auditor’s determination
  • Immediately stop any enforcement collection action such as liens, levies & seizures.

Usually, these types of cases are assigned to an Appeals Officer to resolve before your trial date. In my 20 years of practice, I have a 100% success rate of resolving my clients’ cases with these types of issues “outside of court.”

Have you receive a 90-day notice from the IRS? Don't wait to schedule your free  consultation.

If you are interested in discussing whether a petition in U.S. Tax Court is a good move for you, please schedule a free phone consultation with me.