Steps to Tax Debt Resolution. Call GSA Taxpayer Advocates today 855-472-8294

Tax Litigation

The objective of GSA Tax Advocate Services in every tax controversy is to resolve issues and controversies quickly, efficiently, at the earliest stage and, if possible, without litigation. Our attorneys deal regularly with the IRS, the Treasury, the Department of Justice, and state taxing authorities in an effort to negotiate a resolution of our clients’ tax disputes and cases. At times, however, in order to successfully resolve an outstanding tax debt, we must engage in a litigation process by filing a Complaint or Petition in a federal court of proper jurisdiction.

The majority of tax cases are litigated in the United States Tax Court for one very important reason: in the U.S. Tax Court, taxpayers can commence a case before paying the tax liability asserted by the IRS.

Thus, no assessment of deficiencies of income tax may be made until the taxpayer is given the opportunity of seeking prepayment judicial review in the U.S. Tax Court. A U.S. Tax Court case usually begins after the taxpayer has received a "Notice of Deficiency" from the IRS. The taxpayer must then file a U.S. Tax Court petition within 90 days of the IRS mailing date on the notice. If taxpayer chooses to file a petition in the Tax Court, no collection actions may be taken until the Tax Court has reached its final decision.

The U.S. Tax Court also has jurisdiction to hear certain non-deficiency cases, primarily disputes arising from the denial of collection due process requester request for innocent spouse relief. These cases primarily involve taxpayer opposition to IRS-enforced collection actions (levies and liens) and IRS denials of taxpayer requests for innocent spouse relief, an offer in compromise, penalty abatement or other collection alternatives. Generally, these non-deficiency cases are commenced in the U.S. Tax Court by the taxpayer filing a Tax Court petition after exhausting all IRS Appeal rights pursuant to a request for a collection due process hearing.

If you received a statutory "Notice of Deficiency" and disagree with the deficiency assessment, please call us at 1-855-GSA-TAXHELP (1-855-472-8294) or contact us using the interactive Contact Form contained on this Web site for immediate help.

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