Following an IRS audit or Collection Due Process determination, taxpayers have the right to challenge the IRS in the United States Tax Court. The U.S. Tax Court is a federal trial court with jurisdiction to hear federal tax disputes prior to the IRS issuing a final assessment and proceeding to collections.
If you have received a Notice of Deficiency or Notice of Determination these important documents provide you with the opportunity to present your case to a U.S. Tax Court judge. A Notice of Deficiency allows 90 days (30 days for a Notice of Determination) to file a petition in U.S. Tax Court and challenge the IRS audit determination. While the Tax Court case is pending, the IRS liability is on hold – though interest may accrue on any balance ultimately due.
The United States Tax Court is a specialized Court where taxpayers are challenged and judged by specialized IRS attorneys, IRS appeals officers and Tax Court judges – it is not the same as other state or federal courts and attorneys need special training and knowhow to achieve beneficial results for their clients in the U.S. Tax Court.
Our Denver tax attorneys are led by a former IRS Trial Attorney who spent many years in U.S. Tax Court representing the IRS and, after leaving the government, has resolved tax problems for numerous individuals and businesses. We use our experience on both sides of the tax controversy process (IRS and Taxpayer) to protect taxpayer rights and work with our clients to navigate the intricacies of the tax system and resolve their tax problems.