DISPUTE RESOLUTION PROCESS
01.Core Concepts
• Examination • 30-day letter • Taxpayer can appeal to IRS appeals office within 30 days • IRS appeals office is separate from examination division • If no internal appeal, 90-day letter issued (Notice of deficiency) • Taxpayer has 90 days to: • Pay, or • File a petition in tax court without first paying the tax, or • Pay tax and file suit in District Court or the U.S. Court of Federal Claims.