I have written a number of posts that discuss 30-Day Letters and 90-Day Letters (Statutory Notices of Deficiency) and how they may be appealed to the IRS Appeals Division. This post discusses what happens at the end of an appeal of a 30-Day Letter.
Where 30-Day Letter cases are settled in appeals, the settlement will be documented and the Appeals Officer will ask the taxpayer to waive restrictions on assessment and the collection of any deficiency. That is, the taxpayer will be asked to agree to the immediate “assessment” (a term of art in tax practice) so that the IRS may quickly move forward on the collection of the agreed tax, penalty and interest.
Where no agreement, or only a partial agreement, is reached, a 90-Day Letter (Statutory Notice of Deficiency) will be issued with respect to the disagreed issues. This gives the taxpayer the right to continue a challenge of the disagreed issues in the Tax Court.