Tax Court involves different levels of litigation requiring evidence to support your position with the IRS.  We have experience helping the taxpayer and their attorney identify evidence and support their position with the IRS prior to Tax Court litigation and during Tax Court litigation. 

If you have received a Statutory Notice of Deficiency from the IRS it is very important that you petition the Tax Court for redetermination of the Statutory Notice of Deficiency.  Failure to respond to a Statutory Notice of Deficiency can result in a default deficiency assessment against you and waiving your rights to have the Tax Court reconsider the deficiency.

If you fail to petition the Tax Court upon receiving a Statutory Notice of Deficiency from the IRS within the period allowed by law, you will NOT be allowed to challenge the liability in a Collection Due Process Hearing.  Your administrative remedies with the IRS will be limited.

If you are in a Collection Due Process Hearing (CDP) with the IRS you have the right to petition the Tax Court for review of the Notice of Determination which IRS issues following a CDP hearing.  However, all evidence relating to your CDP hearing must be a part of the administrative case file prior to the close of your CDP hearing.  The administrative case file is maintained by the IRS during the CDP hearing.  The Tax Court reviews a Notice of Determination differently than it reviews a Statutory Notice of Deficiency.

Please call 1-800-447-6181 for a free consultation.