SMAART Tax

Tax Services

Tax Court Representation

Litigation support for unresolved tax disputes

Professional Representation When It Matters Most

When you disagree with the IRS's determination, U.S. Tax Court is often the only venue where you can challenge the assessment before paying. Professional representation can be the difference between a favorable outcome and a devastating one.

Licensed practitioners handle every detail, from petition to verdict, for your strongest defense.

Core Directives

  • Court-Ready Advocacy
  • Dispute Resolution
  • Tailored Strategy

Ready when you are

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Operational Milestones

1

Evaluate

We review the IRS notice, your tax returns, and supporting documentation to establish the legal basis for your dispute.

2

Prepare

We gather evidence, develop legal arguments, prepare court filings, and engage IRS counsel on settlement when it serves your interest.

3

Resolve

We represent you in U.S. Tax Court, then implement the decision and advise on any post-trial compliance obligations.

Included Services & Outcomes

U.S. Tax Court petition preparation and filing
Comprehensive case investigation and evidence gathering
Legal argument development and brief writing
Courtroom representation by licensed practitioners
Audit appeal representation before IRS Appeals Office
Settlement negotiation with IRS counsel
Post-trial compliance and implementation guidance
Ongoing advisory throughout the litigation process

The Stakes in Tax Court Are Real

A single missed deadline, procedural error, or weak argument can result in the full IRS assessment becoming permanent. Professional representation protects your rights and your finances.

Questions

Tax Court Representation FAQ

When do I need Tax Court representation?

You typically need it when you receive a Notice of Deficiency (90-day letter) from the IRS and disagree with their determination. Tax Court lets you challenge the assessment before paying the disputed amount.

What happens if I don't respond to a Notice of Deficiency?

If you don't file a petition with the U.S. Tax Court within 90 days, the IRS assessment becomes final and legally enforceable. You lose your right to challenge the amount in court before paying.

Can SMAART handle audit appeals too?

Yes. We represent clients before the IRS Appeals Office as well as in U.S. Tax Court. Many disputes are resolved at the appeals level without the need for a full trial.

What are the risks of going to Tax Court without representation?

Self-represented taxpayers risk unfavorable outcomes due to missed legal defenses, procedural errors, improper evidence presentation, and inability to effectively negotiate with IRS counsel.

How quickly must we act after receiving a Notice of Deficiency?

The 90-day deadline to file a petition is absolute. We recommend engaging counsel within 14 days so there's time to evaluate, prepare, and file well before the cutoff.

Put SMAART Tax on your tax court representation

Book a free consultation. We'll review your situation, quote a fixed fee, and show you exactly what we'd do differently.