United States Tax Court

There are times when tax controversies cannot be resolved with the Internal Revenue Service or with a state tax authority. The professionals at Andreozzi Bluestein possess extensive experience in litigating tax matters in federal, state, and territorial courts.

United States Tax Court

There are times when tax controversies cannot be resolved with the Internal Revenue Service or with a state tax authority. The professionals at Andreozzi Bluestein possess extensive experience in litigating tax matters in federal, state, and territorial courts.

Most federal tax issues are litigated in the United States Tax Court. This federal court may address tax disputes before the IRS assesses the tax liability.   A taxpayer may commence an action in the Tax Court upon receipt of a Notice of Deficiency from the IRS. The petition must be filed within 90 days (150 days if the taxpayer is not a resident of the U.S.) of the IRS mailing date on the Notice of Deficiency. The Tax Court also has jurisdiction over cases involving collection actions (liens and levies) and IRS denials of taxpayer requests for innocent spouse relief, offers in compromise, penalty abatements or other collection alternatives.

Tax Court judges have expertise in federal tax laws and are therefore uniquely qualified to interpret tax laws and regulations to ensure that taxpayers are taxed fairly by the IRS. Trials are conducted before one judge and without a jury.  Decisions of the Tax Court can be appealed to the United States Court of Appeals so long as the case is not designated by the taxpayer to be a small Tax Court case.

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