---
title: "Prepare the dates for a Tax Court petition from a notice of deficiency"
url: "https://ailawframework.com/practice/taxation/draft-an-objection-to-an-income-tax-assessment-from-the-notice-of-assess/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A26-B15-3-US"
practice_area: "Taxation"
tier: "red"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# Prepare the dates for a Tax Court petition from a notice of deficiency

> 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.

Canonical page: https://ailawframework.com/practice/taxation/draft-an-objection-to-an-income-tax-assessment-from-the-notice-of-assess/united-states  
Last reviewed: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Taxation](https://ailawframework.com/practice/taxation.md) |
| Human involvement | Red: Lawyer writes; AI may check, clarify or collect data |
| 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 | United States |
| Applies to | [Draft an objection to an income tax assessment from the notice of assessment](https://ailawframework.com/practice/taxation/draft-an-objection-to-an-income-tax-assessment-from-the-notice-of-assess.md) |

## Checking plan

- What the AI does: 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.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- No sentence of the petition is written by the tool.
- The 150-day period applies when the notice is addressed to a person outside the United States. Do not assume it.

## Sources

- [26 U.S.C. § 6213 (petition to the Tax Court)](https://www.law.cornell.edu/uscode/text/26/6213) (checked 2026-10-22)
- [IRS Office of Professional Responsibility, Issue 2026-19, Introductory Guidelines for Responsible AI Use in Federal Tax Practice](https://www.irs.gov/pub/opr-taxpros/issue-number-2026-19-introductory-guidelines-for-responsible-ai-use-in-federal-tax-practice.pdf) (checked 2026-10-22)

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*