Key Takeaways The IRS appeals process offers an independent, administrative review of disputed tax issues without going to court The U.S. Tax Court allows you to challenge IRS deficiency determinations before paying the disputed tax Understanding the difference between IRS Appeals conferences and Tax Court petitions is critical to choosing the right strategy Strict deadlines apply — missing the 90-day window on a notice of deficiency eliminates your Tax Court option Most Tax Court cases settle before trial through negotiation with IRS counsel Professional representation from Neil Jesani Tax Resolution significantly improves outcomes in both appeals and litigation When Should You Fight an IRS Decision? Every year, millions of taxpayers receive IRS notices proposing additional taxes, penalties, or adjustments to their returns. While some of these determinations are correct, many are not. The IRS makes mistakes, misinterprets facts, and sometimes applies the law incorrectly. When that happens, you have the right — and often the obligation — to fight back. The question is not whether you can dispute an IRS decision, but how. The two primary avenues are the IRS Office of Appeals (an administrative process within the IRS) and the United States Tax Court (an independent judicial forum). Each path has distinct advantages, requirements, and strategic implications that can dramatically affect your outcome. At Neil Jesani Tax Resolution, we have helped thousands of taxpayers navigate the appeals and litigation process. Our team understands the nuances of both pathways and can help you determine which approach — or combination of approaches — will yield the best result for your specific situation. Call us at (800) 758-3255 for a confidential consultation about your case. Understanding the IRS Appeals Process The IRS Office of Appeals (officially called the IRS Independent Office of Appeals since 2019) is an independent function within the IRS....