Washington, DC tax counsel · Nationwide Tax Court representation
Washington, DC U.S. Tax Court representation.
The firm has an office at 1629 K Street NW, Suite 300 in Washington, DC and represents individuals and closely held businesses in United States Tax Court cases nationwide.
Each matter begins with the notice that opens Tax Court jurisdiction and the last date to file printed on that notice.
Start with the notice and the printed date.
A Notice of Deficiency is the document that lets a taxpayer ask the United States Tax Court to redetermine a proposed deficiency before paying it. The last date to file is the date the notice states.
The Tax Court states that it cannot extend the time for filing a petition. An electronically filed petition must be received by the Court by the time the Court publishes for that last date. Do not use this page to calculate the deadline.
Official source: U.S. Tax Court, Starting a Case
Official source: 26 U.S.C. 6213
Official source: Taxpayer Advocate Service Letter 3219
The work
How the firm approaches a Tax Court case.
Read the notice
Identify the tax years, the proposed deficiency, the last date to file printed on the notice, and whether the document is a Notice of Deficiency or a collection determination.
Confirm the forum from the paper
The date printed on the notice controls. A petition filed by that date asks the United States Tax Court to redetermine the deficiency before the tax is assessed.
Prepare the petition
State the errors assigned to the IRS determination, attach a copy of the notice as the Court requires, and file through DAWSON or on paper under the Tax Court Rules.
Develop the case
Build the factual record, evaluate settlement with IRS counsel, and try the case if it does not resolve.
What a timely petition does.
A case begins with a petition, filed on paper or electronically through DAWSON. The petition should list the errors assigned to the IRS determination. The Court charges a filing fee and may waive it when a petitioner shows an inability to pay.
While a deficiency case is pending, the taxpayer usually does not have to pay the disputed amount first. Interest generally continues to run. The actual next step depends on the notice issued and the Court’s rules.
A Collection Due Process notice of determination is a different Tax Court path. Read IRS collections and IRS Appeals when the paper is a levy or lien hearing determination rather than a Notice of Deficiency.
Questions
Common questions.
What is a U.S. Tax Court case from a Washington, DC office?
The firm has an office at 1629 K Street NW, Suite 300 in Washington, DC and represents individuals and closely held businesses in United States Tax Court cases nationwide. A Notice of Deficiency is the usual paper that opens a deficiency case. The last date to file is the date that notice states.
Can the Tax Court extend the time to file a petition?
The United States Tax Court states that it cannot extend the time for filing a petition. An electronically filed petition must be received by the Court by the time the Court publishes for that last date. Do not use this page to calculate the deadline.
Does a deficiency petition require payment of the disputed tax first?
While a deficiency case is pending, the taxpayer usually does not have to pay the disputed amount first. Interest generally continues to run. The actual next step depends on the notice issued and the Court’s rules.
How is a Tax Court petition filed?
A case begins with a petition, filed on paper or electronically through DAWSON. The petition should list the errors assigned to the IRS determination. The Court charges a filing fee and may waive it when a petitioner shows an inability to pay.
Is a Collection Due Process determination the same as a Notice of Deficiency?
A Collection Due Process notice of determination is a different Tax Court path from a Notice of Deficiency. Start with the collection notice, then read the IRS collections and IRS Appeals pages. An examination report such as Letter 525 may offer Appeals review before a Notice of Deficiency. Letter 3219 is the notice that states the Tax Court date.
If the notice is still an examination letter.
An examination report such as IRS Letter 525 may offer Appeals review before a Notice of Deficiency. IRS Letter 3219 is the notice that states the Tax Court date. Read the current document. An Appeals request does not, by itself, create Tax Court jurisdiction.
Related pages
Related Tax Court resources.
- Tax controversy attorney DCThe Washington, DC tax controversy path from IRS notice to Tax Court and D.C. OTR.
- IRS Letter 3219A Notice of Deficiency states a Tax Court deadline. The date on that notice controls.
- IRS audit defenseReturn to the examination hub when the dispute still concerns an open or recently closed audit.
- IRS AppealsAn Appeals conference is a separate path from a Tax Court petition. Read the current notice before choosing.
- IRS collectionsCollection Due Process determinations can also be reviewed in the Tax Court. Start with the collection notice.
- IRS Letter CheckLook up the code printed on a supported IRS letter.
- Practice areasReview the firm’s federal, District of Columbia, Maryland, and international-reporting scope.
A simple first step
Start with what you know.
Tell me what the notice says and the last date to file printed on it. Send only a high-level summary. Documents can be reviewed later, if needed.
Start here