Tax Law Insights

If a corporate taxpayer receives a statutory notice of deficiency (i.e. a "90-day letter") from the Internal Revenue Service ("IRS"), one of its options is to petition the United States Tax Court for a redetermination of the proposed deficiency. A statutory notice of deficiency tells a taxpayer the IRS has determined that for one reason or another, the taxpayer owes more tax than what they previously reported. Under the Internal Revenue Code ("IRC"), the taxpayer may file a petition with the Tax Court for a redetermination of the deficiency within 90 days (or 150 days if addressed to a ...