Article 1 of the Constitution ensures taxpayers have the right to resolve tax issues in court. Taxpayers have the option to dispute tax issues when they receive a Notice of Deficiency, liens, levies, denial of innocent spouse release, an offer in compromise, etc. The taxpayer must then file a Tax Court Petition within 90 days of the deficiency notice and pay a filing fee in order for the case to be tried in Tax Court. The collection of taxes will be postponed for the duration of the case. Cases are tried in front of a judge with no jury who interprets the IRS codes and regulations and ensures the fair treatment of taxpayers. Cases under $50,000 can be tried in the Tax Court small tax procedure, which is often simpler and faster. However, these cases cannot be appealed. Taxpayers may represent themselves, but it is strongly recommended to utilize the expertise of a tax attorney when appearing before the court. Tax attorneys have the knowledge of tax law issues to properly represent and dispute the IRS findingsin court. Utilizing a tax attorney eliminates the possibility of misrepresenting yourself in court and makes certain that your individual case will be decided on the merits.