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Taxpayer Bill of Rights (Part VIII)

Bill of Right #6: The Right to Finality

Taxpayers have the right to know the maximum amount of time they have to challenge the IRS’s position as well as the maximum amount of time the IRS has to audit a particular tax year. Taxpayers have the right to know when the IRS has finished an audit.

What This Means for You

  • In order to timely challenge a statutory notice of deficiency in Tax Court, you must file your petition within 90 days of the date of the statutory notice of deficiency or 150 days if the taxpayer’s address on the notice is outside the United States or if the taxpayer is out of the country at the time the notice is mailed. If you do not timely file a petition, the amount proposed in the statutory notice will be assessed and you will receive a bill. IRC § 6213

For more information about filing a petition, see the United States Tax Court’s taxpayer information page.

  • If you receive a notice proposing additional tax (statutory notice of deficiency), the notice must include the deadline for filing a petition with the Tax Court to challenge the amount proposed. IRC § 6213(a) (TTT 6/12/18)