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IRS Notice of Deficiency. What Happens If You File In Tax Court?

Updated: Jun 21, 2021

We help clients in the Winchester, VA area get out of trouble with the IRS. We specialize in tax debt resolution. Getting a Notice of Deficiency (NOD) from the IRS can be a scary time. The NOD will assess a proposed tax and give you the opportunity to file in the U.S. Tax Court. What happens, if you don’t think you owe the amount of tax assessed? You will have 90 days from the time of the notice to make the filing in tax court. We generally will advise you to file the petition. Why? If you file in United States Tax Court, and the case has not already been to IRS Appeals, it will be sent there (Internal Revenue Manual, Revenue Procedure 2016-22). Once in Appeals, we can represent you and help you solve the issue.

Once you file the petition with the tax court, the Government will respond. First, you will receive a notification of the receipt of the petition. Then, the answer from the IRS. The tax court does not have the administrative file yet and has no reason to look at any of the details, so the response will be rather generic. Again, if the case has not already been to Appeals, it will automatically be sent there. This is where a good tax debt resolution specialist can help. The taxpayer will then be contacted by an Appeals Officer to schedule a hearing. The hearing will usually be by telephone. This is where you will have a chance to plead your case. Often you will need to send additional documents to the appeals officer to support your claim.

If you miss the opportunity to file in tax court, you will receive the billing notice and it will be considered final. Important reminder: Do not ignore notices from the IRS. We are here to help.

At Tax Debt Resolution Services of Winchester VA, we help you eliminate your IRS issues and the stress the IRS has created in your life and help you get back to doing what you do best! We help our clients in Winchester, VA to resolve their tax debts! If you need assistance please feel free to contact me at 540-662-4432 or

Brian Barto

24 Weems Lane

Winchester, VA 22601


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