IRS NOTICES & ASSESSMENTS
A notice is the Internal Revenue Service telling you that something on your return did not reconcile, or that a balance has been recorded against you. What the notice is called determines what it means, what rights it carries, and how long you have to act.
Got a notice? Read the date first.
The firm will tell you which notice it is, what the Service is asserting, and what clock is already running.
Scheduling does not create an attorney-client relationship. No such relationship exists until the firm has run a conflicts check and both sides have signed a written engagement agreement.
THE NOTICES THAT ARRIVE MOST OFTEN
CP2000
an automated underreporter notice. Third-party data reported to the Service does not match the return. It is a proposed adjustment, not a bill, and it carries a response window. Agreeing to it by silence is a decision, not a default.
Math-error notices
an adjustment made summarily under a limited statutory authority. There is a window in which to request abatement, and letting it pass converts a contestable adjustment into an assessment.
Examination letters
the return has been selected. The record built from here governs everything after it.
Thirty-day letters
the examination has closed with a proposed adjustment and the door to Appeals is open, for a limited period.
Statutory notices of deficiency
the ninety-day letter. The last notice before assessment, and the ticket to the United States Tax Court. The deadline is jurisdictional and no authority can extend it.
Balance-due notices
the tax is already assessed. The matter is in collection, and a different set of rights applies.
WHY THE FIRST RESPONSE DECIDES SO MUCH
A well-built early response frequently ends the matter at the lowest cost it will ever have. Nothing is conceded, the record starts clean, and no forum behind it has closed.
A concession in a reply to a CP2000, or an unexamined agreement to an adjustment, is difficult to unwind — and the taxpayer generally carries the burden of proof on that issue from then on.
The detailed procedure is set out in Processing and the Assessment Station, part of the firm’s tax controversy roadmap.
Agreeing to a proposed adjustment by silence is a decision, not a default.
HOW AN ENGAGEMENT BEGINS
Book a free consultation
Thirty minutes, no charge. Bring the notice — we read it together on that call.
The deadline is identified
Which notice it is, what it asserts, and which forums are still open behind it.
Conflicts check and written engagement
Scope and fee agreed in writing before any work begins.
HOW A CONTROVERSY RESOLVES
The firm takes over
Correspondence with the Service runs through the firm. You stop answering.
The position is built and pressed
Records, authority, and the argument — pressed at the earliest stage that will take it, because that is the cheapest place to win.
Resolution
Closed at examination, settled at Appeals on the hazards, or tried. The firm does not hand the file to anyone to reach the last of those.
If you are unsure which notice you have or when it was issued, the firm will read it with you. Contact the firm through the contact page or call (561) 529-5873. Representative engagements are described on the Experience page.