- What it means
- The IRS is proposing additional tax after a CP2000 you did not resolve. You have 90 days to petition the Tax Court.
- Respond within
- 90 days from the date on the notice
- What to send
- A Tax Court petition within 90 days, or a signed agreement if you agree, or payment.
- Write it
- CP2000 response letter
- When to get help
- Get representation before the 90 days run. The deadline cannot be extended by the IRS or anyone else.
What the letter says
This is the 90-day letter. The CP2000 proposal became a formal deficiency. If you do nothing, the tax is assessed on day 91 and collection begins.
The 90 days
Counted from the date on the notice, 150 if it was addressed to you outside the United States. The Tax Court petition must be filed, not mailed, by that date (a timely postmark counts). No extension exists.
If you agree
Sign Form 5564 (enclosed) and pay. Interest runs from the original due date.
If you disagree
You can still send documents to the IRS and ask it to reconsider, but that does not stop the 90-day clock. File the petition to protect the deadline, then keep working with the IRS. Small cases under $50,000 use simplified Tax Court procedures.
What comes next
Assessment and collection if no petition is filed.
What to gather
- The notice with its date
- The CP2000 and your response, if any
- Your return and the documents supporting your position
- The Tax Court petition form (ustaxcourt.gov)
Write back
The CP2000 response letter tool builds the response in the order the IRS reads it. Fill it in, review it, print it, and send it with copies of the documents above and the notice stub on top.
Before you send anything
This is general information, not tax advice. Situations differ. Check with your tax advisor before you send anything. Nothing on this page creates a client relationship.