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The U.S. Tax Court is a specialized court that hears only federal tax cases at the trial level. Before 1943, the U.S. Tax Court was called the Board of Tax Appeals (BTA). Taxpayers appearing before the Tax Court are not required to pay the disputed tax amount before the case is heard (i.e., "deficiency procedure").
P. 13(a), a decision of the Tax Court may be reviewed by a court of appeals if a notice of appeal is filed with the Tax Court by either the Commissioner or the taxpayer within 90 days after the decision is entered.
You will get as fair and impartial a hearing in tax court as you would in any other federal court. After you file your petition, it will be at least six months until you are called for trial. While most small cases (see immediately below) are decided within one year, regular cases take much longer.
While a petition to redetermine liability is one of the more common reasons you may petition the Tax Court, you can also petition for other issues such as a determination or failure to make a determination by the IRS in your innocent spouse relief case, or a disagreement with the results in your collection due process
Once you receive your notice, you have 90 days (150 days if the notice is addressed to a person who is outside the country) from the date of the notice to file a petition with the Tax Court, if you want to challenge the tax we proposed.
What happens after I file my petition? If you filed a paper petition, you will receive a notice of receipt of petition from the Tax Court by mail acknowledging the filing of the petition. That document will tell you the docket number of your case.
More than 50% of all petitions filed in tax court bring some tax reduction. In cases under $50,000 (called small cases), 47% of all taxpayers win at least partial victories. In cases involving $50,000 or more (called regular cases), 60% come out ahead.
If you owe back taxes and have not been able to work out a solution with the IRS, tax court may be the only option unless you can afford to pay the full amount.