An Overview of U.S. Federal Tax Controversies

This video provides a general overview of the common paths of a U.S. federal tax controversy involving a tax deficiency or refund, from audit through potential litigation. It includes discussion of the administrative IRS Appeals process, the multiple trial-level courts available, where appeal lies, which precedent applies, and some factors that may arise in choosing a tax litigation forum.
As with everything from Break Into Tax, this video does not provide legal or tax advice. It also necessarily omits a lot of detail. For more on U.S. federal tax procedure, see, e.g., the casebook by Prof. Leandra Lederman and Prof. Stephen W. Mazza, Tax Controversies: Practice and Procedure (4th ed. 2018 & Cumulative Supplement).
Contents of this video:
00:00 - Introduction
00:12 - Audit
01:17 - 30-Day Letter
01:42 - IRS Appeals
02:30 - 90-Day Letter
03:23 - U.S. Tax Court Petition
04:15 - Docketed & Nondocketed Appeals
04:42 - Trial Courts
05:00 - The Refund Courts
05:41 - The "Full Payment Rule"
06:12 - Courts of Appeals
07:22 - The Refund Route
08:31 - Forum Shopping
09:03 - Bankruptcy Courts
09:24 - Some Factors in Choice of Forum
12:19 - Precedent
14:43 - Illustration of Tax Litigation Paths
Break Into Tax thanks Les Book and Patrick Thomas for comments on a draft of this video and thanks Connor Hasegawa (McGill Law '23) for editing assistance.
The background image in the thumbnail can be found at en.wikipedia.org/wiki/United_.... Creative Commons License 2.0 (creativecommons.org/licenses/...) applies. We cropped the image and covered it with transparent purple.
Thanks for watching this video and feel free to comment below. Let us know if there are topics you'd like us to cover!
#TaxProcedure #TaxLitigation #TaxControversies #TaxCourt #USTaxCourt #NoticeOfDeficiency #TaxConceptsSimplified #IncomeTax #UStax #BreakIntoTax

[@BreakIntoTax]

Thanks for watching! Please like and share! What do you find most surprising about U.S. federal civil tax procedure?

[@martyhirst7167]

Please help me been trying for 26 hours straight I only need to verify myself to get my taxes from 2020