Federal Tax Court: When the IRS Won't Be Reasonable
Most IRS problems get resolved without a courtroom. But sometimes the IRS takes a position that's just wrong. When negotiation fails, Tax Court is where you make them prove it.
When Tax Court Makes Sense
You received a Notice of Deficiency and disagree with the amount. You lost at an IRS appeal. The IRS denied your Offer in Compromise or installment agreement. In each case, Tax Court gives you a judge who actually listens to both sides.
The Leverage Factor
Here's the part most people miss: you don't have to go to court to benefit from having a lawyer who will. The IRS negotiates differently when they know your attorney has actually tried cases. That changes the math for them.
The Process
You have 90 days from a Notice of Deficiency to petition Tax Court. Miss that deadline and you lose your right. I prepare and file the petition, handle discovery, negotiate with IRS counsel, and if necessary, try the case.
Small Tax Cases
For disputes under $50,000, you can elect the small tax case procedure. It's simpler, faster, and less formal. The tradeoff is that the decision can't be appealed. I advise whether this track makes sense for your case.