A formal notice issued by the IRS after an audit indicating that a proposed deficiency will be assessed unless the taxpayer files a petition with the U.S. Tax Court within a specified time.
Stipulated facts are a set of facts that both parties in a legal or tax dispute agree upon ahead of time, which simplifies the dispute resolution by narrowing down the issues in contention.
An independent 19-judge federal administrative agency that functions as a court to hear appeals by taxpayers from adverse administrative decisions by the Internal Revenue Service (IRS). The Tax Court does not require the taxpayer to pay the alleged deficiency prior to suit. An adverse decision may be appealed as of right to the Court of Appeals and in rare cases to the U.S. Supreme Court.
Trial courts are the first level of court where a case is initially heard and are responsible for examining the evidence and assessing the facts of a dispute. They are courts of original jurisdiction.
