Prepare the dates for a Tax Court petition from a notice of deficiency
Key facts
- Human involvement
- RedLawyer-led
- How AI is used
- Record the mailing date on the notice of deficiency and count 90 days, and 150 days if the lawyer marks the notice as addressed to a person outside the United States. Write no petition.
- What the lawyer must review
- 26 U.S.C. § 6213: within 90 days, or 150 days if the notice is addressed to a person outside the United States, after the notice of deficiency is mailed, not counting Saturday, Sunday, or a legal holiday in the District of Columbia as the last day, the taxpayer may file a petition with the Tax Court for a redetermination of the deficiency. You confirm the mailing date from the notice and you decide whether the 150-day period applies. You write every sentence of the petition. The section restricts assessment, with exceptions in §§ 6851, 6852 and 6861, which you open before you describe collection. Office of Professional Responsibility Issue 2026-19: verify facts before anything is sent.
- Written for / version
- United States versionUS
Who does what
| Role | What they do |
|---|---|
| Assistance | Do not begin AI assistance until the responsible lawyer has defined and confirmed its permitted scope. |
| Lawyer | Perform the substantive analysis and decisions. Independently check any permitted supporting work and approve the exact output for its intended use. |
Checklist
- Confirm the output against the client’s instructions and the complete relevant source material, including omissions or contradictions.
- Resolve exceptions and record the responsible lawyer’s approval of the exact output and intended use.