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Navigating Tax Court: Filing a Tax Court Petition, Burden of Proof, Discovery, Avenues for Settlement, Key Deadlines

Utilizing Tax Court to Resolve Taxpayer Disputes

A live 110-minute CPE webinar with interactive Q&A

This program is included with the Strafford CPE Pass. Click for more information.
This program is included with the Strafford CPE+ Pass. Click for more information.
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Tuesday, March 4, 2025

1:00pm-2:50pm EST, 10:00am-11:50am PST

Early Registration Discount Deadline, Friday, February 7, 2025

or call 1-800-926-7926
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This webinar will guide tax professionals through the Tax Court process. Our panel of federal tax controversy and litigation experts will disclose the criteria for filing a Tax Court petition, the steps in the Tax Court process, and the imperative deadlines taxpayers must meet to successfully resolve controversies with the Internal Revenue Service.

Description

Almost all tax practitioners have assisted with filing or considered filing a Tax Court petition. Taxpayers and their advisers often disagree with IRS determinations or their interpretations of tax legislation. Not confronting these disagreements could prove costly for the taxpayer.

The first and perhaps most crucial determination is whether to file a Tax Court petition. The Tax Court offers the only pre-payment forum to contest the Commissioner’s liability determination. However, taxpayers must consider whether they have a colorable claim for relief, as petitioning the court frivolously can lead to penalties of up to $25,000.

The choice of venue is another principal decision. While the Tax Court offers judges with tax expertise and does not require pre-payment of the asserted deficiency, a refund claim made in the U.S. District Courts or the U.S. Court of Federal Claims could garner a more favorable outcome. District Courts offer jury trials and judges with general, as opposed to tax-specific, knowledge of the law.

Critical to a successful Tax Court outcome are key deadlines that cannot be missed. The taxpayer must receive a valid Notice of Deficiency and make a timely petition request. Once the IRS response is received, the petitioner has 45 days from the date of service to file a reply. Tax professionals preparing returns need to fully grasp the components of the Tax Court, from considering and filing the Tax Court petition through the post-trial brief and opinion to facilitate the resolution of taxpayer issues with the IRS.

Listen as our panel of experienced Tax Court attorneys explains the key components of the Tax Court for taxpayers who disagree with IRS assessments.

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Outline

  1. Navigating Tax Court: introduction
  2. Choice of forum
  3. Ticket to Tax Court
    1. Statutory notice of deficiency
    2. Notice of determination
  4. Tax Court
    1. Filing a timely petition
    2. Discovery procedures
    3. Evidence
    4. Burden of proof
    5. Post-trial briefing/opinion

Benefits

The panel will cover these and other critical issues:

  • Taxpayers who could benefit from and are eligible for an S case (small tax case)
  • When not to file a Tax Court petition including frivolous tax arguments
  • The contents of a Tax Court petition
  • Key deadlines that must be met including filing the petition, trial dates, and taxpayer replies
  • When the taxpayer vs. the IRS bears the burden of proof in Tax Court

Faculty

Vernon, Ethan
Ethan J. Vernon, JD, MTX
Attorney
Asbury Law Firm

Mr. Vernon is an associate at Asbury Law Firm, Tax Counsel. He focuses his practice on federal and state tax...  |  Read More

Heron White, Lauren
Lauren Heron White
Attorney
Asbury Law Firm

Ms. Heron White is an associate at Asbury Law Firm who focuses her practice on federal tax controversy and litigation...  |  Read More

Attend on March 4

Early Discount (through 02/07/25)

CPE credit processing is available for an additional fee of $39.
CPE processing must be ordered prior to the event. See NASBA details.

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Early Discount (through 02/07/25)

CPE credit is not available on downloads.

CPE On-Demand

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