If an audit examination is not settled then the revenue agent (or appeals) will issue a Notice of Deficiency (often called a "90-day letter"). The taxpayer has 90 days to file a Petition in U.S. Tax Court. If a Petition is not filed within 90 days then the proposed tax assessment included in the Notice of Deficiency becomes final. Unlike other federal jurisdictions the taxpayer is not required to pay the outstanding tax to have his or her matter considered. Only a nominal fee is required.
There are a number of advantages to having your matter considered by the U.S. Tax Court. It is an informal process, including discovery, and the IRS district counsel and tax practitioner are generally able to resolve/settle most cases based upon a thorough understanding of the facts and law applicable in your particular tax case.
Robert T. Leonard, Esq., CPA, represents businesses and high net-worth individuals at all phases of the audit examination level — from the initial audit to the trial at U.S. Tax Court. The U.S. Tax Court website can provide a list of all the clients' names whereby the attorney had made an appearance.
Before you hire an attorney to represent you in U.S. Tax Court — or even at any stage of an audit examination — you should ask the prospective attorney how many cases he or she has tried in U.S. Tax Court and request that list as proof. Mr. Leonard has made over 100 appearances in U.S. Tax Court over the last several years. A significant number of Mr. Leonard's clients are referred by their trusted advisors, including CPAs, investment advisors and lawyers
Contact Our Firm
If you have received a Notice of Deficiency (or 90-day Letter) and want a thorough and complete analysis of your tax matter and the right strategies to implement for Tax Court litigation, call Robert T. Leonard directly at the Law Offices of Robert T. Leonard at 818-224-7935 or toll free at 888-408-9486, or fill out the online form on this website for a free, confidential, initial case consultation. We will review your case and your options with their respective benefits and drawbacks, and any alternatives to the legal process that you may have. Our office accepts Visa, MasterCard, American Express and Discover as payment.