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 How do you know if you should
appeal an IRS decision about your taxes?

Taxpayers unable to resolve their tax matters with IRS auditors have the option to litigate their case in federal courts, each with different requirements and attributes. Generally, most tax issues are presented in the United States Tax Court because it is a prepayment forum, meaning that taxpayers can initiate a tax case before paying the tax liability. A case generally begins after the taxpayer has received a Notice of Deficiency from the IRS and the taxpayer petitions the court. Taxpayers must do so within 90 days (150 days if the taxpayer is not a resident of the U.S.) of the IRS mailing date on the deficiency notice.

Tax Court Litigation