IRS notices • Administrative appeals • Tax disputes

Utah IRS Appeals & Tax Court Disputes

Received an IRS audit determination, Notice of Deficiency, or other letter disputing your return? We help Utah taxpayers evaluate assessment disputes, administrative appeals, filing deadlines, and available litigation options.

Call 801-899-6064Request a Free Consultation

Disagree With the IRS? Identify the Notice First.

The number on an IRS notice helps determine your rights and deadlines. An examination proposal, a 30-day appeals letter, and a statutory Notice of Deficiency are not interchangeable. We review your notice and the underlying records to determine whether you may pursue administrative review, a Tax Court petition, or another procedure.

Time-sensitive: A statutory Notice of Deficiency generally provides 90 days from mailing to file a petition in the U.S. Tax Court (often 150 days if addressed outside the United States). Some deadlines and cases differ. Requesting reconsideration does not necessarily extend the deadline. Call 801-899-6064.

IRS Letters and Forms People Search For

Notice CP3219A / CP3219N

Statutory Notice of Deficiency in common individual-return and nonfiler contexts. Review the mailing date and the Tax Court petition deadline printed on the notice.

IRS Letter 531 / Letter 3219

Notices of Deficiency in certain examination cases. These may start the statutory petition period; do not confuse them with a 30-day proposal.

IRS Letter 525 / Letter 950

Common examination letters associated with proposed changes and administrative appeals procedures. Follow the precise instructions and response deadline on your letter.

IRS Notice CP2000

A proposed underreporter adjustment, often based on mismatched income records. A CP2000 is not itself a Notice of Deficiency. A timely factual response can matter.

IRS Form 12203

Request for Appeals Review. A form used in qualifying smaller cases to request IRS Independent Office of Appeals consideration.

U.S. Tax Court Petition

Tax Court petitions must comply with the court’s filing requirements. Court representation is limited to practitioners admitted or otherwise authorized to practice before the court.

IRS Administrative Appeals vs. U.S. Tax Court

Administrative Appeals

The IRS Independent Office of Appeals considers disputes through administrative procedures. Depending on the issue, a protest, Form 12203, supporting records, and legal analysis may be required.

Tax Court Proceedings

In qualifying deficiency cases, a timely Tax Court petition can permit review before payment of the disputed tax. We assess the notice, deadlines, jurisdiction, and availability of admitted Tax Court counsel when court representation is needed.

A legal dispute may involve income characterization, disallowed deductions, business expenses, unreported income, penalties, or procedural issues. The right approach depends on the specific notice and record.

U.S. Tax Court official website · IRS Independent Office of Appeals

What to Have Ready for Your Free Consultation

The IRS notice

Keep the entire letter, date of mailing, envelope when available, and all attachments.

Tax records

Relevant returns, schedules, audit correspondence, supporting documents, and prior appeals.

Deadline information

Tell us the specific response or petition deadline shown on the notice, including any imminent dates.

IRS Appeals and Tax Court FAQs

Is CP2000 the same as CP3219A?

No. CP2000 proposes changes; CP3219A is a statutory Notice of Deficiency that generally starts the Tax Court petition period.

Can I appeal IRS audit results?

Often, but the applicable administrative process and deadline depend on the letter and issue.

Does requesting an IRS appeal extend a Tax Court deadline?

Do not assume it does. Read the notice and obtain legal advice promptly.

Can any attorney represent me in U.S. Tax Court?

Not automatically. Tax Court practitioners must be admitted or otherwise authorized to appear. We assess available representation and appropriate counsel for the matter.

Owe an established IRS balance you cannot pay? Explore Offers in Compromise.

Return to the Tax Practice overview.

Speak With a Utah Tax Attorney

Call Rogers & Russell to discuss your IRS notice, tax debt, and available next steps. Ask about a free initial consultation.

Call 801-899-6064Contact Our Office

Rogers & Russell, PLLC | Pleasant Grove, Utah | 801-899-6064

General information only; not legal or tax advice. No attorney-client relationship is created by contacting the firm. Tax Court appearances require admission to practice before that court or other applicable authorization; availability of representation is assessed individually. No outcome is guaranteed.