Services / U.S. Tax Court Representation

U.S. Tax Court: Dispute What the IRS Says You Owe — Before Paying It.

You've received a Notice of Deficiency (the '90-day letter'), or reached the end of an audit or appeal and the IRS still says you owe. The most important thing to understand is the clock.

The deadline that matters most

A Notice of Deficiency starts a 90-day window (150 days if addressed outside the U.S.) to petition the U.S. Tax Court. That deadline is set by statute and is not extendable — not by the IRS, not by us. The single biggest mistake we see is setting the letter aside to 'deal with later.' Note the date on your notice and treat it as immovable.

Why Tax Court is different

In most disputes you pay first and argue later. Tax Court is the exception: a timely petition lets you contest the liability without paying it up front. Filing also doesn't mean a courtroom showdown — most cases settle with IRS Appeals or Counsel before trial. The petition is often what finally gets a senior, fair set of eyes on a case the examiner got wrong. There are two tracks: a 'small tax case' (S case) for disputes of $50,000 or less per year, and regular case procedures for larger amounts.

What makes BestTaxPro different

You don't need an attorney for Tax Court — you need someone admitted to practice there. Josh is a U.S. Tax Court Practitioner (USTCP), one of the relatively few non-attorneys who passed the Tax Court's admission exam. Most resolution firms refer the case out the moment it heads toward litigation; here, the person who knows your audit and your numbers is the same person who can carry it into Tax Court. We'll also tell you honestly when petitioning isn't the right move.

Our process

A case evaluation focused on the notice and the deadline; preparing and filing the petition within the window if it's the right move; negotiating with Appeals/Counsel; resolution or trial; and follow-through.

This describes how a process works, not a promised result. Outcomes depend on each taxpayer's facts and are not typical or guaranteed.

FAQ

Questions taxpayers ask about this

Received a Notice of Deficiency? Book a case evaluation right away — the deadline can't be extended.

Confidential, no cost, no pressure. We give you an honest read on what's realistic for your facts.