Question 1

What are the stages of resolving a tax dispute?

Accepted Answer

Tax disputes typically progress through: 1) Examination/correspondence with IRS agent, 2) IRS Appeals Office, 3) Tax Court or other federal courts. Most disputes resolve at the examination or Appeals stage.

Question 2

How do I request an IRS appeal?

Accepted Answer

File a written protest within 30 days of receiving a 30-day letter. Include: statement of facts, law and arguments, penalties under examination, and statement of taxpayer agreement/disagreement. For collection issues, file Form 12153.

Question 3

What is the deadline to file Tax Court petition?

Accepted Answer

You must file a Tax Court petition within 90 days (150 days if outside the US) from the date of the Statutory Notice of Deficiency (90-day letter). This deadline cannot be extended.

Question 4

Can I get a penalty removed without going to court?

Accepted Answer

Yes. Request first-time penalty abatement if you have 3 years of clean compliance history. Alternatively, argue reasonable cause (serious illness, death, casualty, inability to get records). The IRS Appeals Office can also reduce penalties.

Step	Action	Timeline
1	Review IRS notice carefully	Day 1-3
2	Gather all supporting documentation	Day 4-14
3	Prepare written response	Day 15-25
4	Submit response before deadline	Day 30
5	Await IRS response	30-90 days
6	Request manager conference if needed	After exam response
7	File appeal if unresolved	30 days from 30-day letter
8	Prepare protest letter	Within appeal period
9	Attend Appeals conference	Scheduled date
10	Consider Tax Court if Appeals denies	90 days from SNOD

Tax Dispute Resolution Calculator

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