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Appeals & Tax Court Petitions

The IRS isn't always the last word. But the clock is running.

When the IRS gets it wrong and won't budge, you can ask someone else to look. Most of those rights come with short, strict deadlines. Miss one, and the option is usually gone for good.

Know your dates

Which letter you got decides your deadline

Look at the letter, then find it here. If you aren't sure, call us and read it to us.

  1. 30 days

    Final notice before they take your money

    Letter LT11 or Letter 1058. You have 30 days to ask for a Collection Due Process hearing. Asking in time generally stops the IRS from taking that money while your case is reviewed.

  2. Within 1 year

    Missed the 30 days?

    You can still ask for an equivalent hearing within one year of that letter. It's the same review, with fewer protections. You usually can't take it to court after.

  3. Any time they act

    Other collection actions

    A lien is a legal claim on your property. A levy is when the IRS takes your money or property. Either one, or a payment plan the IRS turned down or ended, can often go to the Collection Appeals Program. Move fast. Some of these windows are very short.

  4. Usually 30 days

    After an audit

    If you disagree with the changes, the letter usually gives you 30 days to ask for an appeal. It goes to an office that's separate from the auditor.

  5. 90 days

    The 90-day letter

    Its official name is a Notice of Deficiency. It means the IRS plans to charge you more tax. You have 90 days to petition the U.S. Tax Court (150 if the notice is addressed to you outside the U.S.). Treat it as absolute. Late petitions are usually dismissed.

What this is

When the IRS makes a decision you think is wrong, you often have the right to ask for a second look. That might be about how much you owe. Or it might be about what the IRS plans to do to collect.

Most of these appeals go to the IRS Independent Office of Appeals. It’s part of the IRS, but separate from the people who made the decision. Their job is to settle disputes fairly, without a court case. Some cases can go further, to the U.S. Tax Court. That’s a federal court, not part of the IRS.

First, we check what you really owe

An appeal is often the best chance to fight the number itself. In a Collection Due Process hearing, which you request after a final notice, you can sometimes dispute the tax. That’s usually when you never got a formal notice of the tax, or never had another chance to fight it. So before we argue about how the IRS collects, we check whether the bill is right.

Who it fits

  • You got a final notice before they take your money, and the plan is unfair or the bill is wrong.
  • The IRS filed a lien, took money, or turned down a payment plan.
  • An audit ended with changes you don’t agree with.
  • You got a Notice of Deficiency.

What you’ll need to do

Send us the letter right away, and anything that backs up your side. We’ll file the written request, build the case, and handle the calls and meetings. Most appeals happen by phone, video, or mail.

How long it takes

It varies a lot. Some collection appeals move in weeks. Hearings and audit appeals often take months. A Tax Court case can take longer still. We’ll tell you what to expect for your case.

What can go wrong

The deadline passes. This is the big one. Many of these rights end on a fixed date, and the IRS can’t give you more time. The Tax Court can’t extend its own deadline either.

The wrong kind of appeal. Each kind can cover different issues. Picking one can sometimes keep you from raising the same issue in another. We choose with that in mind.

Appeals says no. It’s their call. Some decisions can then go to court. Others are final. We’ll tell you up front which kind you’re in.

Tax Court

Who does what if your case goes to court

The Tax Court is where you can fight a tax bill before you pay it. Here's how we handle it.

01

We protect your right to petition

We make sure the deadline isn't missed and the right papers go in on time. That keeps your day in court open.

02

An attorney argues the case

We can't argue cases in Tax Court. If yours needs to be argued, we coordinate with an attorney admitted there.

03

You can file it yourself

The Tax Court lets people file their own petition, without a lawyer. In a pinch, that alone can save your rights.

04

Most cases still settle

Many cases get worked out with the IRS before a judge ever hears them. We keep pushing for that.

Got a letter that mentions Tax Court or 90 days? Call us today. That deadline doesn't bend.

Your next move

What to do right now

Questions? (501) 209-7393
  1. 1

    Find the date on the letter

    Your deadline counts from that date, not from when you opened it.

  2. 2

    Look for these words

    Collection Due Process, Tax Court, 90 days, LT11, or Letter 1058. Each one means a deadline.

  3. 3

    Don't just call the number on the letter

    A phone call usually doesn't protect your appeal rights. A written request filed on time does.

  4. 4

    Book a free consultation

    We'll tell you which right you still have, and how much time is left.

Straight answers

Questions about Appeals & Tax Court Petitions

Do I have to go to court?

Usually not. Most appeals are handled on paper, by phone, or by video. Even cases filed in Tax Court often settle before trial.

Can you go to Tax Court with me?

We can't argue cases there. We help protect your right to petition, and we coordinate with an attorney admitted to the Tax Court if your case needs one. You can also file the petition yourself.

What if I already missed the deadline?

Some rights end for good. Others leave a backup. For example, a missed 30-day hearing request can often become an equivalent hearing within a year. And after an audit, you may be able to reopen the case with new proof. Let's look at what's still open.

Does an appeal stop the IRS from collecting?

Sometimes. A hearing request filed within the 30 days generally pauses the levy it's about. Other appeals may not stop collection at all. We'll tell you which one you're in.

Picture a few months from now

You open the mail without your stomach dropping.

The IRS calls us, not you. The balance has been fought down to what you actually owe, if anything, and whatever's left has a plan in writing built on your real numbers. And you've stopped carrying this alone. That's what we're working toward, starting with one free conversation.

(501) 209-7393

Private · Confidential · No obligation

Based in Central Arkansas, serving all 50 states

Talk to Katrina: (501) 209-7393