The filing of a petition with the United States Tax Court, in response to a Statutory Notice of Deficiency, also known as a 90-Day Letter, requires skill to ensure the proper placement of the issues on appeal before the Tax Court. Internal Revenue Manual – 4.8.9 Statutory Notices of Deficiency
Subsequent to the timely filing of a petition, the mater will be assigned to a Conferee, an employee of the Revenue Service, for issue development and discussion of resolution of the matters on appeal.
This process allows for an informal discussion and exchange of documentation and other information among the Conferee, counsel and the taxpayer.
It is very common that these discussions will result in a proposed resolution to which counsel and the taxpayer can agree. Such a resolution has the effect of avoiding the costly litigation process.