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IRS Notice of Deficiency: What It Means and How to Respond

Getting a letter from the IRS is never fun—but a Notice of Deficiency (also called a “90-day letter”) is one you can’t afford to ignore. It’s the IRS’s way of saying: We think you owe more tax than you reported. The good news is that you have options. Here’s what you need to know and what to do next.


What Is a Notice of Deficiency?

  • It’s a formal legal notice that the IRS believes you owe additional tax.
  • It is not a bill—it’s your chance to dispute the IRS before they assess the tax.
  • You have 90 days (150 if you’re outside the U.S.) from the date on the notice to act.

Why You Might Receive One

  • The IRS disallowed deductions or credits you claimed.
  • They believe you underreported income.
  • An audit or third-party reporting (like W-2s or 1099s) didn’t match your return.

Your Options After Receiving a Notice

  1. File a Petition with the U.S. Tax Court
    • Must be done within 90 days.
    • Lets you challenge the IRS without paying first.
  2. Agree and Pay
    • If you agree with the IRS, sign the waiver and pay.
    • This stops interest and penalties from growing.
  3. Negotiate or Settle
    • You may still be able to work out a deal, such as an Offer in Compromise or an installment agreement.
  4. Get Professional Help
    • This is where a tax attorney can make a big difference.

Why You Should Consider a Tax Attorney

While CPAs and enrolled agents are excellent for tax preparation and audits, a Notice of Deficiency is a legal matter. Here’s why a tax attorney may be the better choice:

Tax AttorneyCPA / Enrolled Agent
Can represent you in U.S. Tax CourtCannot represent you in Tax Court (unless they’re also admitted to practice there)
Trained in tax law and legal strategyTrained in accounting, compliance, and tax preparation
Can negotiate settlements and handle complex disputesCan assist with audits, filings, and IRS correspondence
Attorney-client privilege protects your communicationsCPA-client privilege is limited and weaker in IRS disputes

Bottom line: If your case could end up in Tax Court—or if you’re facing significant tax liability—a tax attorney is often the best advocate.


Practical Steps to Take Immediately

  1. Read the notice carefully—note the deadline.
  2. Gather your records—income statements, receipts, prior returns.
  3. Decide quickly whether you agree or want to challenge.
  4. Consult a tax attorney—especially if the amount is large or you believe the IRS is wrong.
  5. Don’t ignore it—after 90 days, the IRS will assess the tax and begin collections.

Final Takeaway

A Notice of Deficiency is serious, but it’s also an opportunity. You have the right to challenge the IRS before paying a dime. Acting quickly—and with the right professional help—can protect your finances and give you the best chance at a fair outcome.

Disclaimer:

This post does not constitute legal advice and does not create an attorney-client relationship, it is merely a general discussion of points of the law and may not be complete or up to date. Please contact our office for a consultation to discuss how tax laws may be relevant to your specific situation.

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