A notice of deficiency is also known as a 90 day letter. Sometimes its called a “ticket to the Tax Court.” It is the last letter that the IRS must send to all taxpayers in income and estate tax cases before the IRS can begin collecting the tax. Once the notice of deficiency is sent you have 90 days to file a Petition with the United States Tax Court. If you file a Petition then in virtually all cases the IRS may not collect any money from you until you have had a chance to have a judge hear your case. Failing to file a Petition with the Tax Court will result in the loss of very important rights. A Petition should always be filed if there is any dispute that the taxes set forth in the notice of deficiency are not correct.

If you receive a notice of deficiency you should immediately contact a tax lawyer since a CPA, or an enrolled agent can not file a Petition for you in Tax Court unless they have passed a special exam given by the Tax Court. According to one source only 202 non-attorneys have been admitted to practice before the Tax Court since 1943.