Request A Case Evaluation Or Tax Resolution Development Plan

Received A Notice Of Deficiency To Appeal IRS Proposed Adjustments To The U.S. Tax Court? Let us help you

Before adjustments from an audit can be finally assessed, a taxpayer must be given the right to appeal to the United States Tax Court if the taxpayer should disagree with the findings of the IRS audit. The Appeals Office (or in certain cases the IRS agent) will issue a “90-day Letter” to a taxpayer, which essentially provides the taxpayer with up to 90 days to file a petition with the Tax Court and have his or her case heard by a judge.

At this stage, any professional who is to represent you in Tax Court must be admitted to practice before Tax Court. Requirements for practicing in Tax Court include passing a very difficult income tax exam. Most non-lawyers are not qualified to practice before Tax Court and would, therefore, be unable to provide this kind of tax audit help or represent you. However, a qualified IRS audit attorney can help you.

The United States Tax Court is a Federal court of record established by Congress under Article I of the Constitution of the United States. Congress created the Tax Court to provide a judicial forum in which affected persons could dispute tax deficiencies determined by the IRS prior to payment of the disputed amounts. The jurisdiction of the Tax Court includes the authority to hear tax disputes concerning notices of deficiency, notices of transferee liability, certain types of declaratory judgment, readjustment and adjustment of partnership items, review of the failure to abate interest, administrative costs, worker classification, relief from joint and several liability on a joint return, and review of certain collection actions.
Unlike appeals to other Federal courts, there is no requirement to pay any of the disputed tax liability in order to have your case heard in Tax Court.

The Tax Court is composed of 34 presidentially appointed judge-members. Trial sessions are conducted and other work of the Court is performed by these judges, by senior judges serving on recall, and by special trial judges. All of the judges have expertise in tax law and apply that expertise in a manner to ensure that taxpayers are assessed only what they owe, and no more. Although the Court is physically located in Washington, D.C., the judges travel nationwide to conduct trials in various designated cities.
A case in the Tax Court is commenced by the filing of a petition. The petition must be filed within the allowable time limit. The Court cannot extend the time for filing which is set by statute. A $60 filing fee must be paid when the petition is filed. Once the petition is filed, payment of the underlying tax is ordinarily postponed until the case has been decided.

In certain tax disputes involving $50,000 or less, taxpayers may elect to have their case conducted under the Court’s simplified small tax case procedure. Trials in small tax cases are generally less formal and result in a speedier disposition. However, decisions entered pursuant to small tax case procedures are not appealable.

Cases are calendared for trial as soon as practicable (on a first in/ first out basis) after the case becomes at issue. When a case is calendared, the parties are notified by the Court of the date, time, and place of trial. Trials are conducted before one judge, without a jury. Only those practitioners that are admitted to the Bar of the Tax Court may practice before this court.

Usually a case is settled by mutual agreement without the necessity of a trial. However, if a trial is conducted, in due course a report is ordinarily issued by the presiding judge, setting forth findings of fact and an opinion. The case is then closed in accordance with the judge’s opinion by entry of a decision.

By engaging our tax representation services, you can be assured that your petition and each stage of the litigation process will be persuasive because we know how to present your case with legal argument and tax authority.

Description: The Law Offices Of Jeffrey B. Kahn, P.C. has helped many people minimize or avoid adjustments from IRS by pursuing litigation and negotiations with the U.S. Tax Court. Working with a tax attorney is the best bet for minimizing adjustments that would create liability to the IRS.

    Request A Case Evaluation Or Tax Resolution Development Plan

    Get a Tax Resolution Development Plan from us first before you attempt to deal with the IRS. There are several options for you to meet or connect with Board Certified Tax Attorney Jeffrey B. Kahn. Jeff will review your situation and go over your options and best strategy to resolve your tax problems. This is more than a mere consultation. You will get the strategy or plan to move forward to resolve your tax problems! Jeff’s office can set up a date and time that is convenient for you. By the end of your Tax Resolution Development Plan Session, if you desire to hire us to implement the strategy or plan, Jeff would quote you our fees and apply in full the session fee paid for the Tax Resolution Development Plan Session.

    Types Of Initial Sessions:

    Most Popular GoToMeeting Virtual Tax Development Resolution Plan Session
    Maximum Duration: 60 minutes - Session
    Fee: $375.00 (Credited if hired*)
    Requires a computer, laptop, tablet or mobile device compatible with GoToMeeting. Please allow up to a 10-minute window following the appointment time for us to start the meeting. How secure is GoToMeeting? Your sessions are completely private and secure. All of GoToMeetings solutions feature end-to-end Secure Sockets Layer (SSL) and 128-bit Advanced Encryption Standard (AES) encryption. No unencrypted information is ever stored on our system.

    Face Time or Standard Telephone Tax Development Resolution Plan Session
    Maximum Duration: 60 minutes - Session
    Fee: $350.00 (Credited if hired*)
    Face Time requires an Apple device. Please allow up to a 10-minute window following the appointment time for us to get in contact with you. If you are located outside the U.S. please call us at the appointed time.

    Standard Fee Face-To-Face Tax Development Resolution Plan Session
    Maximum Duration: 60 minutes - Session
    Fee: $600.00 (Credited if hired*)
    Session is held at any of our offices or any other location you designate such as your financial adviser’s office or your accountant’s office, your place of business or your residence.

    Jeff’s office can take your credit card information to charge the session fee which secures your session.

    * The session fee is non-refundable and any allotted duration of time unused is not refunded; however, the full session fee will be applied as a credit toward future service if you choose to engage our firm.