Has the IRS sent you a Notice of Deficiency? If so, you may need representation in the United States Tax Court. The Utah tax lawyer team at Pearson, Butler & Carson, PLLC, (“PEARSON BUTLER Law”) are experienced in Tax Court matters and can help you determine the best course of action in your situation.
If you would like to appeal a Notice of Deficiency, you are required to file a petition with the Tax Court within 90 days of the date that the IRS mailed the deficiency notice to you. Your case will be dismissed if a you file your petition late, assuming the IRS mailed you a valid notice of deficiency was mailed to you. The petition must comply with a number of specific IRS guidelines. Once your case is docketed with the Tax Court, you will have an opportunity to appeal the Notice of Deficiency through the IRS docketed appeals program, and the Tax Court will provide a notice of the date and location of the trial as well as pretrial instructions several months prior to trial.
Fortunately, a Utah tax lawyer can negotiate a settlement to settle tax disputes before the case reaches trial. The goal in each case is to persuade the IRS representative that a settlement offer makes sense for both you (the taxpayer) and the government. Negotiation and settlement through your tax attorney is often preferred by taxpayers as the United States Tax Court is not authorized to use equitable principles to mitigate harsh results in deficiency cases.
Tax Attorney ServicesAt PEARSON BUTLER Law, we assist in various tax matters:
- Tax Court Litigation
- IRS Appeals
- IRS Audits
- Criminal Tax Defense
- Payroll Taxes
- Trust Account Taxes
- Offer in Compromise
- IRS Collections
- Installment Agreements
- Innocent Spouse Relief
- Offshore Voluntary Disclosure and Foreign Bank Accounts
- State Sales Tax Audits
- Tax Planning
- Nonprofit taxation and compliance