The United States Tax Court has jurisdiction of federal tax issues. One of the most common cases over which the United States Tax Court has jurisdiction is tax deficiencies. A deficiency is an amount of tax that the taxpayer allegedly owes the IRS in excess of any amounts reported on the return.

The notice of deficiency is a taxpayer’s “ticket” into Tax Court. To initiate litigation, the taxpayer must file a petition with the Tax Court for a redetermination of the deficiency. That petition must be filed within 90 days of the mailing of the deficiency notice. If no petition is filed, the tax is assessed. But when the petition is filed, litigation commences. The action takes the form of a lawsuit in which the taxpayer is suing the IRS.

Unlike other venues, a taxpayer need not pay the amount in dispute in order to litigate in tax court. If you dispute the tax liability assessed by the IRS, let Mr. DeBlis help you evaluate the best course of action. It is best to hire an attorney when proceeding with a Tax Court petition to ensure your rights are protected and to obtain the best result.