Notice Review
Identify the determination, the stated deadline, the disputed issues, and the procedural options available.
Federal Tax Litigation
When an IRS Dispute Needs a Courtroom Strategy
A timely Tax Court petition may preserve your opportunity to challenge an IRS determination.
The Forum
When disagreements with the IRS cannot be resolved through the examination or appeals process, taxpayers may petition the United States Tax Court to challenge the IRS’s determinations.
Court rights may depend on the type of notice received and the deadline stated in it. Prompt review of correspondence is important when litigation may be an option.
Petition Strategy
Evaluate whether and how to preserve rights before the Tax Court.
Case Preparation
Organize the legal position, documents, witnesses, and settlement posture.
Resolution or Trial
Pursue settlement discussions where appropriate while preparing for advocacy if the dispute continues.
Representation Includes
Focused Support at the Stage You Are In
- Deficiency cases
- Trial preparation
- Settlement negotiations
Who This Helps
Start With the Facts That Matter
This page is for taxpayers who have received an IRS determination and need to understand whether a Tax Court petition, settlement strategy, or other response may be appropriate.
A Tax Court consultation begins with the IRS notice, the stated filing date, the issues in dispute, prior examination or appeal history, and the records that support the taxpayer’s position. Time-sensitive correspondence should be reviewed as soon as possible.
Prepare for a Consultation
Helpful Documents to Have Available
You do not need every document before contacting the firm. Bringing the materials below, when available, can make the first conversation more efficient.
- The notice of deficiency, notice of liability, or other IRS determination
- Prior examination reports, appeals correspondence, and settlement communications
- Tax returns, workpapers, financial records, and supporting documents
- A chronology of IRS contacts, filings, and important dates
Common Questions
United States Tax Court Representation FAQs
What kinds of cases are heard by the United States Tax Court?
The Tax Court hears certain disputes with the IRS, including deficiency cases. Whether it is the right forum depends on the notice received and the circumstances of the case.
Does a Tax Court matter always go to trial?
Some cases may be resolved through settlement negotiations, but every matter has its own facts, procedural posture, and risks.
Why does the notice deadline matter?
Court rights may depend on the type of notice received and the deadline stated in it. Prompt review is important when litigation may be an option.
What should I bring for a Tax Court consultation?
Bring the IRS notice, any prior appeal documents, tax filings, supporting records, and a timeline of the matter. Those materials help identify the procedural posture and questions to evaluate.
Related Tax Representation
Explore a Related Next Step
Appeals Representation
Administrative resolution may be available before or alongside a litigation decision.
Criminal Tax Defense
Confidential counsel for higher-risk tax investigations and related concerns.
Confidential Consultation
Get a Clear View of Your Next Step.
Prompt guidance can help you understand your options, deadlines, and priorities.