In the United States, when taxpayers have disputes with tax authorities that cannot be resolved through administrative means, they have the right to file a lawsuit in Tax Court to challenge unfavorable decisions made by the Internal Revenue Service (IRS). The U.S. Tax Court is a specialized judicial body established to handle tax-related cases, operating independently from the IRS to ensure fair adjudication and proper legal interpretation of tax disputes.

Under U.S. law, taxpayers enjoy a significant advantage when filing petitions with the Tax Court: they are not required to pay the disputed tax amount before initiating litigation. This provision offers substantial convenience for resolving tax disputes involving asset assessments, allowing taxpayers to legally protect their rights without facing immediate financial pressure. This approach not safeguards taxpayers' economic interests but also creates a more equitable environment for litigation.

However, before filing a petition, taxpayers must ensure they have received an official Notice of Deficiency, commonly known as the "90-day letter." The issuance of this notice marks the formal commencement of the dispute between the taxpayer and the IRS, and taxpayers should treat it with utmost seriousness. If taxpayers disagree with the IRS determination, they must file their petition with the Tax Court within 90 days of receiving the notice. Notably, for taxpayers residing outside the United States, this filing deadline may be extended to 150 days to accommodate their circumstances and allow proper time to prepare their appeal.

During Tax Court proceedings, taxpayers may need to appear multiple times to present evidence and information supporting their case. Therefore, it's advisable for taxpayers to retain experienced tax attorneys to ensure smooth proceedings and maximum protection of their legal rights. Professional legal representation not helps taxpayers better understand the legal process but also increases the likelihood of success in their case while ensuring proper administration of justice. Ultimately, properly utilizing the Tax Court system provides taxpayers with an effective remedy to fairly protect their tax-related rights and interests.