U.S. Tax Court Representation
Litigate Your Tax Dispute Without Paying First
The U.S. Tax Court is the only forum where you can challenge an IRS deficiency without paying first. If you've received a Notice of Deficiency (90-day letter), you have 90 days to file a Tax Court petition—or you'll lose your right to litigate before payment.
90-Day Deadline is Absolute
Miss it and you lose your right to challenge before paying
Real Results: Tax Court Case
"Business owner received $312K deficiency notice. IRS disallowed business expenses claiming inadequate documentation. Filed Tax Court petition, produced additional records during discovery, negotiated stipulated settlement for $41,000—87% reduction."
*Illustrative scenario. Tax Court outcomes depend on evidence and legal arguments.
When to Use Tax Court
Good Candidates
- • Received Notice of Deficiency (90-day letter)
- • Have documentation to support your position
- • Disagree with IRS on facts or law
- • Can't afford to pay before challenging
- • Appeals failed or was unsatisfactory
Consider Alternatives If
- • You agree with the assessment
- • Issue is collectability, not liability
- • Amount is small (under $5,000)
- • You have no documentation
- • Better served by OIC or installment agreement
Tax Court Process
File Petition
Within 90 days of Notice of Deficiency
IRS Answer
IRS responds to your petition
Settlement Conference
Most cases settle here (90%+)
Trial/Decision
If no settlement reached
Small Tax Case Procedure
Eligibility (IRC § 7463)
- • Disputed amount under $50,000 per year
- • Simpler, less formal procedures
- • No formal discovery required
- • Decision is final (no appeal)
Benefits
- • Faster resolution
- • Lower legal costs
- • Less formal hearing
- • Still same $60 filing fee
IRS Authority & References
Related Resolution Services
Received a 90-Day Letter?
Time is critical. You have only 90 days from the Notice of Deficiency to file a Tax Court petition. Contact us immediately for a case evaluation.
Book a Case Analysis