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THE INTERNAL REVENUE SERVICE AND THE NOTICE OF DEFICIENCY OR THIRTY DAY LETTER (“30 DAY LETTER”) — WHAT IS THIS IRS NOTICE OR LETTER? WHAT SHOULD YOU DO? WHO CAN HELP YOU?

A Notice of Deficiency (“90-day letter”) is sent by the Internal Revenue Service (“IRS”) to officially allege that a taxpayer owes additional taxes. If you receive a Notice of Deficiency, you need to contact an Atlanta tax law firm immediately. When choosing which Atlanta tax law firm to contact, you should consider choosing an Atlanta based law firm with an experienced Atlanta tax attorney, IRS tax lawyer, and/or Atlanta tax law expert.

Once you receive the Notice of Deficiency, you have 90 days from the date of the Notice (not 90 days from the date you receive the Notice) to consult an Atlanta tax attorney and/or Atlanta tax expert to assist you in considering your options and addressing the serious nature and implied allegations of this IRS Notice. The reason I suggest that your seek out counsel from an Atlanta tax attorney and/or Atlanta tax expert, is that the United States Southeastern Headquarters for the Internal Revenue Service (“IRS”) is located in Atlanta as are the Federal Tax Court and the Federal Court for the Northern District of Georgia. This has several advantages in that resolving your IRS tax matter may involve a meeting with an Atlanta Based Internal Revenue Service Agent (“IRS Agent”) in the City of Atlanta. Additionally, should you need to resolve any Internal Revenue Service (“IRS”) dispute through the administrative tax law process in Tax Court or through litigation in Federal Court; you will likely be doing so in Atlanta, GA.

Regardless of whether you believe the Internal Revenue Service (“IRS”) is correct, the amount alleged in the Notice of Deficiency is due and owing. As such, I strongly recommended you consult an Atlanta tax attorney, Atlanta IRS tax lawyer, and/or Atlanta tax expert. In my many years of practicing in an Atlanta tax law firm as an Atlanta tax attorney, I have seen all too many people misread or not understand these IRS letters and cast them aside only to find out later that this alleged IRS Notice of Deficiency has dire consequences because IRS Tax Notice went disregarded.

As general rule, when the IRS involved and it is not in the common course of your dealings with them, you should err on the side of caution and understand what exactly it is you have received from them and what your options are. Moreover, many people throw these IRS Notices aside only to have this action come back to haunt them with extraordinarily expensive and dire consequences. You should have an Atlanta tax lawyer, Internal Revenue Service (“IRS”) tax lawyer and/or Atlanta tax expert advise you on exactly what the Notice you received is, and exactly what it means for you. It is altogether true; most people do not understand the nature of these letters and what exactly this particular “Notice” is telling you. Furthermore, assuming you are correct in your evaluation of the alleged Notice of Deficiency, you should consider having an Atlanta tax attorney and/or Atlanta tax expert negotiate an installment payment agreement or formulate “Offer in Compromise” on your behalf. This of course, is assuming you qualify for these forms of payment plans. Nevertheless, it is better to work with the Internal Revenue Service (“IRS”) at the earliest time you can and before it is too late. Once the IRS has spent time, monies, and resources tracking you down and seeking and forcing payment from you, they are much less likely to negotiate, if they will negotiate at all.



The fact remains, most likely your prior attempts to reach a settlement with the IRS have failed, or you would not have received a Notice of Deficiency. Moreover, as a general rule, the IRS does not send a Notice of Deficiency until after the IRS auditing agent has not reached a settlement with you, and until after you have been sent a “30 Day Letter” (“Thirty Day Letter”). This “30 Day Letter” request you to send a letter to the IRS within 30 days stating your position and asking the IRS to reconsider the IRS agent’s findings. At this time, it is likely will be the case that the “30 Day Letter” (“Thirty Day Letter”) is sent after any negotiation period has ended. As such, you should take immediate action upon receipt of a Notice of Deficiency and contact an Atlanta tax lawyer and/or or Atlanta tax expert as the IRS has put you on the defense. You must stand up and speak for yourself or this Notice of Deficiency will become conclusive and binding on you and the tax liability asserted by the IRS is deemed final. Please know you only have 90 days from the date of the Notice of Deficiency to reach a settlement so you should engage an Atlanta tax attorney and/or Atlanta tax expert and should do so immediately upon receipt of the Notice of Deficiency. If you do nothing, and choose to ignore these matters, you will not lose your to contest the position the IRS has taken against you.

If you find yourself in any of the positions above, or are wondering or confused about any matters at all, it is my strong opinion you seek the advice of an Atlanta tax attorney or Atlanta tax expert immediately upon receipt of any Notice of Deficiency or “30 Day Letter.” (“Thirty Day Letter”)

The Libby Law Firm
specializes in legal representation in tax matters involving Notice of Deficiency, “30 Day Letter” (“Thirty Day Letter”), IRS Assessments, IRS Assessments, Failure to Pay Taxes, Back Taxes Due, Payroll Taxes, Tax Negotiations, Installment Plans, Offers in Compromise, and other tax matters, controversies, disputes and litigation. Our Main Office is conveniently located in the heart of Buckhead in Atlanta, Georgia, near the intersection of Piedmont and Roswell Roads. Please feel free to call us at (404) 467-8611 , to discuss your options, or send us a message through our confidential Web Site form. An experienced Atlanta tax lawyer and/or Atlanta tax expert would be glad to assist you.