Kentucky Tax Lawyer Research Library
Search Kentucky statutes, federal tax provisions, Treasury regulations, agency guidance, and plain-English explanations of tax procedure.
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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.
The regulation under section 6212 addresses issuance of deficiency notices and joint-return notice rules.
The Collection Due Process regulation uses detailed questions and answers to implement notice, hearing, levy, and review rules under section 6330.
A written protest should define each disputed adjustment, state the relevant facts, apply authority, and preserve the administrative record.
A Tax Court petition invokes a specialized federal court's jurisdiction and must follow the statute, current court rules, and accepted filing procedures.
Section 6330 governs notice and hearing rights before many IRS levies and defines the issues Appeals may consider in a Collection Due Process case.
Section 6213 establishes the general petition period following a statutory notice of deficiency and restricts assessment while that period remains open.
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