Tax Law:

U.S. Tax Court Litigation

The U.S. Tax Court was established by Congress to allow taxpayers the opportunity to dispute tax deficiencies with the IRS in a judicial forum without having first to pay the disputed amount. The U.S. Tax Court has authority over a variety of matters including the review of the following:

  • IRS collections activities
  • IRS decisions to deny a request for a penalty abatement, offer in compromise or innocent spouse relief
  • IRS assertion of transferee liability

The U.S. Tax Court also handles requests for declaratory relief, classification of workers as independent contractors or employees and partnership allocation disputes.

The U.S. Tax Court is comprised of 19 judges, who have extensive knowledge of tax law. These judges are in charge of interpreting the Internal Revenue Code and similar regulations and making sure taxpayers are treated fairly by the IRS. Although the U.S. Tax Court is stationed in Washington, D.C., its judges routinely conduct trials in various locations throughout the country.

Typically, a case in the U.S. Tax Court commences when a taxpayer files a petition and pays a filing fee. After doing so, the taxpayer will not have to pay the disputed tax amount until the trial is over. Taxpayers are not awarded the right to a trial by jury in U.S. Tax Court. Rather, their case will be carried out before a single judge.

If the deficiency amount is less than $50,000, the taxpayer can choose to have their case conducted under a simplified small tax case procedure. These trials are typically less formal and resolutions are reached more quickly. However, decisions made through the small tax case procedure cannot be appealed.

Most tax cases are resolved through a joint agreement between the IRS and the taxpayer before they ever reach trial. However, should your case reach the U.S. Tax Court, and you are not satisfied with the resolution, you can file an appeal with the U.S. Court of Appeals. If you have a tax issue that you would like resolved through the U.S. Tax Court, fill out our free case evaluation form. Our tax lawyers are ready to review your case, at no cost to you, to determine whether we can help you settle your taxation problem with the IRS.

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