What We Are Seeing: A Rise in Notice of Deficiency Letters — And Why You Must Act Fast

In recent months, we’ve seen a noticeable uptick in Notice of Deficiency letters issued by the IRS. If you’ve received one, this is not just another notice to set aside or casually respond to—it’s your one shot to formally dispute the liability before it becomes final.

A Notice of Deficiency is often referred to as a “90-day letter” for good reason: you have exactly 90 days from the date on the notice (not when you receive it) to file a petition in U.S. Tax Court. There are no extensions. Missing that deadline generally locks in the liability, leaving collection options on the table for the IRS—including levies and liens.

We often hear, “But I wrote a letter to the IRS explaining everything.” Unfortunately, responding to the IRS does not preserve your rights. The only way to stop the clock is by filing a petition in Tax Court. And if you don’t, you lose your ability to challenge the tax before paying it.

That’s why we strongly encourage clients to take action immediately upon receiving this notice. Filing a Tax Court petition is often the best opportunity to resolve the issue. Once in court, many cases settle faster, more favorably, and often for less cost—without needing a full trial—because they’re reviewed by specialized IRS attorneys and handled through the court’s settlement process.

At Orlando Tax Law, we handle Tax Court cases regularly and know how to navigate both the legal and strategic elements involved. If you or someone you know has received a Notice of Deficiency, don’t wait. Reach out immediately—we can help you file a timely petition and fight for the best resolution.