When the IRS accuses someone of owing federal taxes, the taxpayer can dispute the IRS’s claim in the United States Tax Court. The Tax Court is the only forum for tax litigation outside of bankruptcy without first having paid the alleged taxes. It also deals with other issues such as collection due process, liens and levies, and IRS denials of innocent spouse relief, offers-in-compromise, and penalty abatement.
The Tax Court is physically located in Washington, D.C., but the trials sometimes occur in different cities. It has 19 judges that are appointed by the U.S. President, along with senior judges and special trial judges. There are no jury trials.
Some states, such as Arizona and Minnesota, also have their own tax court. These tax courts typically deal with issues concerning state taxes, municipal taxes, and property taxes. These tax courts are different from the United States Tax Court, which is the federal tax court.
Our firm has had significant success in Tax Court. Our most well-known case is Dixon v. Commissioner of the IRS. In that case, a tax refund was ordered for 1,300 airline pilots, which was and remains the largest test case reversal. See cases, civil tax investigation, or contact us.