One court in America hears your tax dispute before you pay: the United States Tax Court. Its door opens through one document on one deadline, and the move - filing the petition - mostly buys something better than a trial. Here is how to run it.
Count the 90 Days Today
The Notice of Deficiency starts 90 days to petition - the least forgiving deadline in the tax system: no extensions, no good-cause exceptions, the clock running from the notice date rather than the day you opened the envelope. Day 91 is too late forever, and the dispute then requires paying first and suing for refund. So the first move with any 90-day letter is arithmetic: find the date on the notice, count, and calendar the filing with margin. Certain collection determinations also reach the court on their own 30-day clock.
File the Petition, Choose the Track
The petition itself is short: the notice identified, the disputed determinations stated, the relief requested - precision matters more than length, because issues omitted can be conceded. For disputes of $50,000 or less per tax year, the small-case election opens the S docket: relaxed evidence rules, simplified procedure, trials conducted as conversations, genuinely navigable by ordinary people - at one permanent price, no appeal for either side. Right for most small factual disputes; worth ten minutes of counsel's review where anything is unusual.
Understand What Filing Buys
Mostly: leverage. Petitioned cases route to IRS Appeals and Chief Counsel for settlement evaluation under litigation risk, and issues that were brick walls in the audit become negotiable when a judge might rule on them - the overwhelming majority of petitions settle without trial. If trial comes, it is a bench trial before a judge who hears nothing but tax, with the stipulation culture shrinking most cases to one or two genuine issues first. I am admitted to practice before the court, and the honest preview holds for nearly everyone: you will probably never testify, the petition is the move, and the deadline is absolute. If the 90-day letter is on your desk, count the days right now - then call me.