When facing off against the IRS for whatever reason, there is always a process for escalation wherein if your case is not resolved you can seek the attention of a higher authority.
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Sometimes, it is in the best interest of the taxpayer to make a refund claim instead of file a deficiency action in the Tax Court.
Litigation in the Tax Court is unique among all other forums in that the process involves various pre-trial stipulations made by both parties. In fact, the Tax Court requires litigant to submit to extensive pretrial stipulations, which are embodied in Tax Court Rule 91.
When contemplating filing a petition for redetermination, the taxpayer must be sure to comply with certain procedural and jurisdictional requirements. If the taxpayer fails to do so, there is a risk that the deficiency litigation will be invalid.
When you receive a statutory notice of deficiency from the IRS, you can file for a deficiency tax litigation or a refund tax litigation proceeding.