Tax Court petition filing by nonattorneys.
The Tax Adviser › Vol. 32 Nbr. 9, September 2001
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Summary
CPA firms filing for clients
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Extract
Tax Court petition filing by nonattorneys.
It is no secret that many CPA firms are filing Tax Court petitions for their clients. Filing a Tax Court petition is simpler than filing a protest with Appeals. A tax practitioner who can prepare a protest can surely prepare a Tax Court petition. Over 50% of all Tax Court cases and over 90% of "small tax cases" under Sec. 7463 are pro se. For the nonattorney tax practitioner, being able to prepare and file a petition is a useful skill against the tolling of a 90-day letter.
Under normal audit procedures, the IRS issues a 30-day letter, giving a taxpayer 30 days to file a protest and request an Appeals hearing. On the taxpayer's failure to request a hearing or following an Appeals hearing, the Service issues a 90-day letter, giving the taxpayer 90 days to file a Tax Court petition before collection pr...See the full content of this document
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