Notices of Deficiency are official notices from the IRS that are sent to you via certified mail with return receipt requested. The document is extremely important and should not be ignored under any circumstances. You are notified of unpaid tax liabilities you have by the IRS, including interest and penalties. The IRS plans to assess you for these unpaid taxes. If you have not filed a tax return for more than one year, the IRS can issue a Notice of Deficiency.
You may decide to settle your IRS problem by paying the alleged deficiency if the amount listed in the Notice of Deficiency is small enough. A Petition can be filed in the United States Tax Court if an amount listed on a Notice of Deficiency is incorrect.
United States Tax Courts accept two types of petitions against the IRS, called “S” cases and regular cases. You may choose to treat your tax case as a small tax case (also known as an “S” case) if your proposed penalty plus interest for each year is $50,000.00 or less. A collection case, including penalties and interest, cannot have a total unpaid tax liability over $50,000.00 throughout all years in order to be classified as an “S” case. There are fewer rules of evidence in “S” cases than regular cases. A “S” case however does not have the right to appeal any adverse decision. A regular case before the United States Tax Court may be considered if your proposed liability does not meet any of the “S” case criteria, or if you would like the opportunity to appeal any adverse outcome.
Deficiencies must be addressed within 90 days of the date listed in the Notice of Deficiency. Due to the United States Tax Court’s legislative status rather than its constitutional nature, its jurisdiction is strictly limited to the 90-day period. You cannot file a Petition with the United States Tax Court if you do not timely or properly file it within the 90 day period.
As an attorney for the IRS, IRS Trouble Solvers Seattle regularly represented the United States government in the United States Tax Court. If you have received a Notice of Deficiency, please contact IRS Trouble Solvers, LLC.
If you have received a Notice of Deficiency from the IRS, immediate action is required. IRS Trouble Solvers™ in Seattle stands ready to assist with your Notice of Deficiency. Your BEST bet to resolve your IRS Debt!®