Andrew Belter and William Schmidt have a discussion on two items regarding client deadlines in taxes.

-What to do when a client shows up with a short deadline for the IRS or Tax Court?  This might put an attorney in a bind regarding the work to do in a short amount of time.  Entering an appearance in court is easy for an attorney to do, but requires the judge’s approval to for the attorney to withdraw from the case.  In other instances, there may be a scramble to file paperwork to the IRS.  What are some considerations necessary to trust the client?

-Also, there is the issue of premature assessments.  The U.S. Tax Court is backed up on processing petitions they have received.  In the meantime, the IRS has not received notices that those petitions were filed.  Their Collections department may then believe there is no petition and incorrectly send out a notice regarding the deficiency.  To address this issue, there is an email address to contact and provide your case number in the situation:  [email protected]


Here is the recent press release from the Tax Court on premature assessments:  08162021.pdf (


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