Calculate deadlines for U.S. Tax Court proceedings, IRS collection actions, tax appeals, and administrative tax procedures.
Tax court petition or IRS proceeding
Federal CourtsPetition in response to deficiency notice
90 daysFrom date of deficiency notice (150 days if outside US)
CDP hearing request
30 daysFrom date of collection notice
Administrative appeal to IRS Appeals
30 daysFrom examination report or proposed adjustment
Administrative refund claim filing
3 yearsFrom original return due date or 2 years from payment
Consider pursuing IRS Appeals Office review before filing a Tax Court petition. Appeals conferences can often resolve disputes without litigation costs and preserve all legal rights.
Tax Court has jurisdiction only over certain tax matters and only before payment of the disputed tax. Refund suits must be filed in federal district court or Court of Federal Claims after payment.
Small Tax Cases (S cases) offer streamlined procedures for disputes of $50,000 or less but waive appeal rights. Consider whether the simplified procedures outweigh the loss of appellate review.
Tax Court judges actively encourage settlement, and the court offers various settlement procedures including settlement conferences and mediation programs to resolve disputes efficiently.
Determine the type of tax matter: Tax Court petition, IRS collection due process, appeals office procedure, or refund claim litigation.
Input the date of the IRS notice of deficiency, collection action, or other triggering event that establishes the deadline calculation starting point.
Identify whether the matter requires a Tax Court petition, administrative appeal, or federal district court action based on the type of tax dispute.
Consider unique tax procedure rules including the Tax Court Rules of Practice, IRS procedural regulations, and jurisdictional requirements.
Apply the appropriate deadline: 90-day petition period, 30-day collection due process request, or 2-year refund claim limitation.
Ensure proper jurisdiction, exhaustion of administrative remedies, and compliance with Tax Court procedural requirements including case filing and service.