Tax Litigation

Have you received a Statutory Notice of Deficiency from the IRS proposing an assessment of taxes following an audit? If a taxpayer disagrees with the determinations to adjust tax set forth by the IRS in a Statutory Notice of Deficiency, the venue to challenge the proposed assessment is typically the U.S. Tax Court.  Taxpayers have only 90 days (150 days for taxpayers residing outside the U.S.) to file a petition with the U.S. Tax Court to challenge the IRS. The right to challenge an IRS assessment can be lost if a petition is not timely.

  • Petitions and Trials in the United States Tax Court – Litigation in United States Tax Court may be required when certain types of tax controversies cannot be resolved at the audit or Appeals level. Tax Court litigation is usually commenced after the filing of a petition with the Court after the issuance of a Statutory Notice of Deficiency in a wide range of issues including income, estate or gift taxes and in some other limited areas. The jurisdiction of the Tax Court can also be invoked when a taxpayer wishes to challenge the manner in which an IRS revenue officer is attempting to collect an assessed tax.


  • Limited Scope Consultation – The attorneys at Mopsick Carrere, LLP handle Tax Court Litigation matters from cradle to grave. In some cases, a taxpayer may be handling a case on his own or the taxpayer may have an existing representative handling the case and want to consult on Tax Court procedure, strategy, or the underlying tax law of an issue in dispute. The attorneys at Mopsick Carrere, LLP often consult with taxpayers and their existing representatives on specific issues that can include:


  • Trial Procedure

  • Settlement and Case Closing procedures

  • Addressing Collections following conclusion of a Tax Court matter

  • Tax Court Motions

  • Tax Court Discovery