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8.2.2.1
(10-24-2007)
Introduction to 90-Day Cases in Appeals
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When a notice of deficiency is issued, the case is considered a 90-day case from the date the notice is issued until a petition
is filed with the United States Tax Court or until expiration of the 90-day period. This section covers how to process 90-day
cases that are both resolved and not resolved during the 90-day period.
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A notice of deficiency is generally referred to as a 90-day letter.
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if there is a deficiency in the case as defined in IRC 6211, IRC 6212 authorizes mailing a notice of deficiency to the taxpayer's
last known address using certified or registered mail.
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