Advisory
Business Consulting
Strategic guidance to help your business navigate challenges and seize opportunities for growth.
Learn MoreTax Services
Tax Court Representation
When the IRS disputes your tax position, SMAART's licensed practitioners prepare your case and represent you in U.S. Tax Court.
Professional Representation When It Matters Most
Receiving a notice of deficiency from the IRS can be one of the most stressful events a taxpayer faces. When you disagree with the IRS's determination, U.S. Tax Court is often the only venue where you can challenge the assessment before paying. Having professional representation is not just advisable, it can be the difference between a favorable outcome and a devastating financial result.
SMAART Company's Tax Court Representation services are led by U.S. Tax Court Practitioners and Enrolled Agents with deep experience in audit appeals, complex tax disputes, and courtroom advocacy. We provide comprehensive case preparation, gathering evidence, building legal arguments, and representing you through every phase of the process.
Without representation, taxpayers risk unfavorable outcomes, missed defenses, and the stress and uncertainty of navigating a complex legal system alone. SMAART develops tailored strategies for each unique case and provides ongoing support from pre-trial preparation through post-trial compliance.
Core Directives
Court-Ready Advocacy
Dispute Resolution
Tailored Strategy
Ready When You Are
Operational Milestones
01
Evaluate
Review the IRS notice, your tax returns, supporting documentation, and the legal basis for your dispute.
02
Prepare
Gather evidence, develop legal arguments, prepare court filings, and build a comprehensive case strategy.
03
Negotiate
Engage with IRS counsel to explore settlement opportunities before trial when it serves your interest.
04
Represent
Present your case in U.S. Tax Court with full legal representation by our licensed practitioners.
05
Resolve
Implement the court's decision, advise on any post-trial obligations, and ensure ongoing compliance.
The Stakes in Tax Court Are Real
A single missed deadline, procedural error, or weak argument can result in the full IRS assessment becoming permanent. Professional representation protects your rights and your finances.
Included Services & Outcomes
U.S. Tax Court petition preparation and filing
Comprehensive case investigation and evidence gathering
Legal argument development and brief writing
Courtroom representation by licensed practitioners
Audit appeal representation before IRS Appeals Office
Settlement negotiation with IRS counsel
Post-trial compliance and implementation guidance
Ongoing advisory throughout the litigation process
Don't Face the IRS Alone in Court
Tax Court is a legal proceeding with real consequences. SMAART's licensed practitioners handle every detail, from petition to verdict, so you have the strongest possible defense.
FAQ
Questions &
Answers
Get answers to the most common questions about our tax court representation services.
You typically need Tax Court representation when you receive a Notice of Deficiency (90-day letter) from the IRS and disagree with their determination. Tax Court allows you to challenge the IRS's assessment before paying the disputed amount.
If you don't file a petition with the U.S. Tax Court within 90 days, the IRS assessment becomes final and legally enforceable. You lose your right to challenge the amount in court before paying.
Yes. We represent clients before the IRS Appeals Office as well as in U.S. Tax Court. Many disputes are resolved at the appeals level without the need for a full trial.
Taxpayers who represent themselves risk unfavorable outcomes due to missed legal defenses, procedural errors, improper evidence presentation, and inability to effectively negotiate with IRS counsel.
The 90-day deadline to file a Tax Court petition is absolute, miss it and you lose your right to challenge the IRS assessment before paying. We recommend engaging counsel within 14 days of receiving a Notice of Deficiency so there's time to evaluate, prepare, and file well before the cutoff.
Get Representation You Can Trust
If you've received a Notice of Deficiency or need to challenge an IRS decision, contact SMAART's Tax Court team today.
Schedule ConsultationRelated Services
Explore Our Other Services
01 / 02
01 / 02
Related Insights
From the SMAART Blog
Taxes
Sales Tax Nexus for Small Businesses: When You Have to Collect Tax in Other States
Sales tax nexus rules expanded dramatically after the Wayfair decision. Small businesses selling across state lines, especially online, may have sales tax obligations in states they've never physically visited.
Read Article
Taxes
The Small Business Tax Planning Calendar: What to Do Each Quarter
Good tax outcomes come from consistent attention throughout the year, not heroic efforts at filing time. A quarterly tax planning calendar keeps small businesses ahead of deadlines and surprises.
Read Article
Taxes
Amended Tax Returns: When to File One and How the Process Works
Filing an amended return is often the right response to a discovered error or a missed deduction. Understanding when to amend, when not to, and how the process works prevents small issues from becoming larger ones.
Read Article