1. Federal Tax Problems Call for Different Responses
A proposed assessment calls for a different response from a final unpaid balance. The IRS notice should guide the next step.
Filing Errors and Unreported Income
A W-2 or 1099 mismatch may call for an explanation or amended return. Compare source records with the original filing first. Amending a return does not automatically end an examination.
Audits and Proposed Adjustments
The IRS may question reported income, deductions, or credits. IRS audit defense involves reviewing requests, providing evidence, and disputing adjustments. An audit alone does not establish fraud.
Assessed Debt, Liens, and Levies
An assessed balance raises collection questions. A federal tax lien is a claim against property; a levy permits seizure under applicable procedures. Payment records and collection notices reveal which response options remain open.
2. A Federal Tax Case Review Starts with the Notice
A case review connects the IRS position to the relevant taxpayer, period, and records. The notice is only the starting point.
Agency, Tax Type, and Taxpayer
Identify the taxpayer, years, and tax type. Businesses must confirm which entity filed the return. Corporate debts do not automatically create personal liability for owners.
Notice Number and Response Date
Record the letter or CP number, mailing date, and deadline. Preserve prior submissions. Examination letters, deficiency notices, and final levy notices trigger different procedures.
Returns, Transcripts, and Financial Evidence
IRS transcripts show payments, assessments, and account activity. Compare them with returns, ledgers, and bank records. Address each discrepancy with relevant evidence.
3. IRS Resolution Options Depend on the Dispute
Disputing tax owed and requesting time to pay are separate tasks. The IRS proceeding determines which options remain available.
Examination Responses and Administrative Appeals
A proposed adjustment may be challenged with evidence and legal arguments. Eligible disputes can reach the IRS Independent Office of Appeals through the protest process. An administrative protest does not automatically extend the Tax Court petition deadline.
Payment Plans and Offers in Compromise
Installment agreements may allow payment over time. An Offer in Compromise can settle eligible debt for less than the full amount, subject to IRS review. Tax debt resolution also addresses collection options and penalties.
Limits on Challenging an Existing Assessment
A collection hearing does not always reopen the underlying tax liability. Previous notices and opportunities to contest the assessment can restrict review. Check that history before choosing a payment or litigation strategy.
4. Filing Deadlines and Federal Court Options
Different IRS notices carry different filing periods. Identify the notice and the governing rule before calculating any deadline; discussions with the agency may not extend it.
The 30-Day Letter and Deficiency Notice
IRS Letter 525 generally allows 30 days from the letter date to request Appeals review. A statutory deficiency notice generally allows 90 days after mailing to petition the U.S. Tax Court, or 150 days when addressed to a person outside the United States. Statutory last-day rules apply.
Collection Due Process Hearings
A qualifying lien or levy notice generally allows 30 days to request a Collection Due Process hearing. Timely requests can preserve Tax Court review of the Appeals determination. A later equivalent hearing does not provide that same judicial review right.
Tax Court and Refund Litigation
San Francisco hosts Tax Court trials but is not a petition-filing office. DAWSON electronic filings are due by 11:59 p.m. Eastern Time. Refund suits may proceed in federal district court, including the Northern District of California when venue is proper, generally after full payment and a timely administrative refund claim, subject to exceptions.
5. Federal, California, and City Tax Duties Remain Separate
Federal tax rules apply nationwide. State and city agencies handle separate obligations, even when the same income is involved.
California Franchise Tax Board Matters
The Franchise Tax Board administers California income and corporation taxes. Federal audit adjustments may trigger separate state reporting or amendment requirements. An IRS appeal does not replace a California response.
San Francisco Business Tax Obligations
The city's Treasurer & Tax Collector administers business taxes, including the Gross Receipts Tax. Filing obligations depend on the tax year and business activity. A state and local tax review can address these separate issues.
6. Legal Representation Follows the Case Stage
A federal tax attorney may review notices, test proposed assessments, prepare protests, or provide representation in eligible proceedings. Services should reflect the actual dispute rather than promise a tax reduction.
IRS Representation and Business Exposure
IRS Form 2848 authorizes qualified representatives for specified matters and years. Unpaid trust fund taxes may create personal liability under 26 U.S.C. § 6672 when its statutory requirements are met. Corporate status alone does not decide responsibility.
Fees and Documents for Case Review
Fees depend on the issues, records, and whether Appeals or litigation is involved. Confirm the engagement scope. Gather notices, returns, transcripts, and submission records; identify the earliest deadline.
13 Nov, 2026
