26 U.S.C. § 6212: The Statutory Notice of Deficiency
Section 6212 authorizes the IRS to mail a notice of deficiency, commonly called a 90-day letter, before assessment of many disputed income, estate, gift, and excise taxes.
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Section 6212 authorizes the IRS to mail a notice of deficiency, commonly called a 90-day letter, before assessment of many disputed income, estate, gift, and excise taxes.
Section 7525 extends a limited confidentiality privilege to certain tax advice from federally authorized tax practitioners, with significant exceptions.
Section 6301 directs the Secretary to collect taxes imposed by the Internal Revenue Code.
Section 6322 generally dates the federal tax lien from assessment and continues it until the liability is satisfied or becomes unenforceable by lapse of time.
Section 6323 governs when an unfiled federal tax lien is invalid against specified third parties and contains extensive priority and protection rules.
Section 6325 provides different mechanisms for releasing a lien, discharging particular property, and subordinating the federal lien.
Section 6331 authorizes levy after demand and nonpayment, subject to notice, timing, statutory restrictions, and exceptions.
Section 6332 generally requires a person possessing property subject to levy to surrender it, with specified exceptions and consequences.
Section 6334 lists categories of property exempt from federal tax levy and limits the effect of other exemption laws.
Section 6343 requires release of a levy in specified circumstances, including unenforceability, facilitated collection, installment agreements, and economic hardship.
Section 6501 supplies the general limitation period for assessment and numerous exceptions involving omitted income, nonfiling, fraud, and agreed extensions.
Section 6502 generally permits collection by levy or court proceeding within ten years after assessment, subject to suspensions and extensions.
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