“You have the right to petition, within 90 days, the United States Tax Court if you receive a formal “Notice of Deficiency”. This notice is jurisdictional, in other words you cannot petition the Tax Court without it. The United States Tax Court is an independent court that was created by Congress to allow taxpayers to dispute adverse IRS determinations. It is not part of the Internal Revenue Service and the Tax Court is independent of it. There are courts of this nature in 60 U.S. cities. Michael Ablan has been admitted to practice law before all of the United States Tax Court’s since 1980.