Statutory Notice of Deficiency
If a tax deficiency has been determined, the Service is authorized to
send a notice of such deficiency to the taxpayer or his/her properly
authorized representative. Taxpayers or their representatives have 90
days (150 days if the notice is addressed to a person outside the United
States) to petition the Tax Court for a redetermination of the deficiency.
If a petition is not filed within the 90-day (or 150-day) period, the law
requires IRS to assess the tax and bill the deficiency. When responding
to a statutory notice of deficiency it is important to respond directly to
the office which issued the notice. Publication 556, Examination of
Returns, Appeal Rights, and Claims for Refund
, explains the
assessment process in more detail.