Guide · Tax

Tax Controversy for Individuals: A Comprehensive Guide to Notices, Audits, Appeals, and Collection

26 U.S.C. § 6201

Type
Guide
Jurisdiction
National
Date
2026-02-21
Topic
Tax

This guide covers an individual tax controversy from the first notice through collection resolution years later. Part 1 explains assessment and why it is the hinge of the entire system. Parts 2 and 3 cover examination and the Independent Office of Appeals. Part 4 covers the notice of deficiency and the ninety-day petition period. Part 5 covers refund litigation and the full payment rule. Parts 6 through 9 cover liens, levies, collection due process, and the collection alternatives. Parts 10 through 12 cover penalties and abatement, innocent spouse relief, and the limitation periods that govern everything. Part 13 covers the taxpayer rights that are operational rather than aspirational, and Part 14 sets out practice notes by role.

Tax Controversy for Individuals: A Comprehensive Guide to Notices, Audits, Appeals, and Collection

Tax > Tax Controversy | Published 21 February 2026 - Updated 18 August 2026 | UpLaw - uplaw.us

Assessment is the hinge. Before it, the taxpayer has pre-payment access to a court. After it, the government can collect and the taxpayer's options narrow sharply. Nearly every strategic decision in this guide is a decision about which side of assessment to be on.

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