IRS Notice Notice of Deficiency
90-Day Letter
This is your legal right to challenge the IRS in Tax Court before paying. Miss this deadline and you lose that right.
Tax Attorney · Villanova University School of Law · Admitted in Delaware, New Jersey, United States Tax Court
What Happens If You Ignore Notice Notice of Deficiency
If you don't petition Tax Court within 90 days, you must pay first and sue for a refund later. You lose valuable rights.
Every day you wait, penalties compound, interest accrues, and your options shrink. The IRS does not negotiate well with silence — they escalate.
What You Should Do Right Now
This deadline is absolute. Contact us immediately to evaluate whether Tax Court is the right option for you.
- 1
Do not call the IRS phone number on the notice until you've spoken with an attorney — anything you say can be used against you.
- 2
Gather every page of the notice plus any prior IRS correspondence about the same tax year.
- 3
Call a senior tax attorney (not just any CPA or preparer) so attorney-client privilege protects the conversation.
- 4
Respond before the deadline — even a properly filed request for an extension or hearing buys you protection.
Why a Tax Attorney — Not a "Tax Relief" Company
Your conversations are legally protected. CPAs and enrolled agents do not have this protection in criminal or sensitive matters.
Our attorneys have negotiated thousands of cases. We know which IRS agents to call and what arguments actually work.
Properly filed responses can immediately pause levies, garnishments, and asset seizures while we negotiate.
If your case escalates to Tax Court, U.S. District Court, or criminal exposure, we can represent you there. Most firms cannot.
Costly Mistakes People Make With Notice Notice of Deficiency
Assuming it's a mistake and throwing it away — the IRS computers move on whether you respond or not.
Paying the amount listed without verifying it — the IRS is wrong more often than people realize.
Calling the IRS without preparation and admitting facts that worsen the case.
Signing a payment agreement that locks in penalties you could have abated.
IRS Notices Related to Notice of Deficiency
These are the notices the IRS most often sends before, after, or alongside a Notice of Deficiency. Read the related ones to understand where you are in the collection sequence.
Tax Resolution Services That Resolve a Notice of Deficiency
Senior tax attorneys at McCauley Law Offices use these strategies to stop, settle, or unwind a Notice of Deficiency notice.
Primary Sources & Authority
We cite the underlying IRS publications and statutes so you can verify everything on this page.