Fighting the IRS is Slow. Taking them to Tax Court is Faster.
Skip the WaitPetition Tax Court
There’s another option. As a United States Tax Court Practitioner, Paul Channo can petition the U.S. Tax Court directly, taking your case out of the IRS’s hands and in front of an independent judge. It’s often the more direct path to resolution, and it’s one very few tax professionals in the country are licensed to offer you.
What is Tax Court Representation?
When the IRS sends you an IRS Notice, you have a choice:
- Pay what the IRS says you owe, or
- Petition the U.S. Tax Court and let a judge (not an IRS employee) decide your case.
Filing that petition is a specific legal action, and most tax preparers, and even most CPAs and EAs, aren’t authorized to do it. Paul is.
We evaluate your IRS notice or letters, determine whether a petition is the right move for your situation, and if it is, we file it and represent you through the process. This way, you’re arguing your case to a neutral third party instead of negotiating with the same agency that sent you the bill.
How Do Taxpayers End Up in Tax Court?
These are the situations where going to Tax Court becomes the strategic option worth considering:
- Notices of deficiency
- Audit adjustments you disagree with
- Penalties you believe were assessed incorrectly
- Tax litigation or controversy where the administrative process has stalled or isn’t moving in your favor
What To Expect: How Tax Court Representation Works
Review: We review your IRS notice and determine your deadline and your options.
Petition: If Tax Court is the right move, we prepare and file your Tax Court petition with the U.S. Tax Court.
Representation: Paul represents you directly before the Court as your U.S. Tax Court Practitioner. You don’t face this alone, and you don’t face it through a preparer who has to hand your case off to someone else if it escalates.
Resolution: We pursue the strongest resolution available to you, whether that’s a negotiated settlement before trial or a decision from the Court.
Deadlines here are strict. Missing your deadline means forfeiting your right to Tax Court. If you’ve received an IRS Notice, time matters.
Why Choose Paul Channo?
Paul Channo is a United States Tax Court Practitioner, a non-attorney tax professional who has passed the Tax Court’s own bar examination and been admitted by the Tax Court as a member of the bar to represent taxpayers directly in Tax Court proceedings. In the courtroom, the Court makes no distinction between a USTCP and an attorney. Both are addressed as “Counsel,” and both can prosecute a civil case against the IRS through trial.
Special Distinction
There are less than 300 USTCPs nationwide, compared to tens of thousands of tax attorneys and tax lawyers. Most people, including most tax professionals, will never work directly with an attorney.
Not Limited by State
Narrower, Deeper Specialization
Unlike a general practice attorney, a USTCP’s authority is focused specifically on U.S. Tax Court matters. Deficiency cases, civil tax controversies, and tax litigation before the Tax Court.
Frequently Asked Questions
Do I need an attorney to go to Tax Court?
No. A United States Tax Court Practitioner, like Paul Channo, is authorized to represent taxpayers directly before the U.S. Tax Court without being an attorney. In the courtroom, the Court makes no distinction between a USTCP and an attorney, and both are addressed as “Counsel.”
What's the difference between an IRS appeal and a Tax Court petition?
An IRS appeal keeps your case inside the IRS’s own process, arguing to IRS personnel on the IRS’s timeline. A Tax Court petition takes your case out of the IRS’s hands and puts it in front of an independent judge instead.