19Jan 2023 by Pat Geddie
Litigating a Case in Tax Court: A Litigation Tutorial

Litigating a Case in Tax Court: A Litigation Tutorial

Tax Law
By Anthony Diosdi The Internal Revenue Service or “IRS” audits hundreds of thousands of tax returns every year. At the conclusion of these tax audits, on many occasions, the IRS proposes to assess additional tax liabilities and penalties against the individual who was subject to the audit. These proposed adjustments could be wrong and the only way to contest the IRS’s proposed assessments without paying the liability is to petition the Tax Court. This article will discuss step-by-step how to contest an IRS audit before the United States Tax Court.Although there are exceptions to this rule, anyone considering disputing an audit result in Tax Court must wait until they are issued a notice of deficiency by the IRS. A notice of deficiency states the tax liability they believe a taxpayer…
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24Sep 2019 by Pat Geddie
Bringing a Case Before the United States Tax Court A to Z Part III. How to Proceed with a Tax Court Trial

Bringing a Case Before the United States Tax Court A to Z Part III. How to Proceed with a Tax Court Trial

Tax Law
By Anthony Diosdi Although the vast majority of cases brought before the Tax Court are settled, some cases proceed to trial. If you are considering bringing a case to trial before the Tax Court, it is important to be familiar with the order in which a trial proceeds. Although no rigid format applies in every case, a basic framework has evolved within which a trial will be conducted. This framework is subject to change depending on the preference of the presiding judge. In my experience, a significant number of individuals do not take their trials before the Tax Court seriously. Many individuals believe the IRS has the burden of proof in Tax Court cases so they do not properly prepare for trial. Others, believe that Tax Court controversies rarely proceed…
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