90-Day Letter

90-Day Letter

A letter that the IRS sends to a taxpayer after an audit. The letter states that the audit has found inconsistencies or other errors in the tax returns and that the taxpayer will have to pay more unless he/she can show that the audit is in error. The letter derives its name from the fact that the taxpayer has 90 days to dispute the results of the audit before reassessment occurs.
References in periodicals archive ?
If the taxpayer properly files a Tax Court petition in response to the 90-day letter, the case normally will be referred to an Appeals case manager for resolution prior to a Tax Court hearing.
98-54 lists three situations that can result in a rescission of a 90-day letter and several in which the IRS will not grant rescission.
Along with the substitute return, you will generally receive a notice of statutory deficiency (commonly referred to as a 90-day letter), which will give you 90 days to file an appeal with the Tax Court.
With the signing of the non-binding, 90-day letter of intent, Aria Health and Jefferson begin a process of due diligence that will enable each organization to learn more about the other.
In such cases, committees should send the "90-day letter" to the service provider, requesting specific information about compensation.
If the IRS exam team is not persuaded by the explanations provided by SnowFun, then the typical IRS process would lead to a 30-day letter, allowing for the IRS appeals process, followed by a 90-day letter (a statutory notice of deficiency).
It is noteworthy, however, that in Offiler, the court compared a notice of determination to a 90-day letter with respect to its jurisdiction.
Further, we recommend that Congress also repeal the ill-conceived "hot interest" provision of section 6621(c), which provides a further two-percent increase in the interest rate on large corporate underpayments (an underpayment of more than $100,000) 30 days following the issuance of a notice of proposed adjustment (a "30-day letter") or a notice of deficiency (a "90-day letter").(4)
Subsequently, the IRS mailed a notice of deficiency (90-day letter) that stated that as a result of the audit, an additional tax was being assessed.
6212(a) the IRS can issue a statutory notice of deficiency, also known as a 90-day letter, when it determines a deficiency in an income or estate and gift tax liability.
If no agreement is reached, a Statutory Notice of Deficiency (90-day letter) is issued.
(1) Section 6621(c0 provides for a two-percent increase in the interest rate on large corporate underpayments (an underpayment of more than $100,000) 30 days following the issuance of the proposed adjustment (a "30-day letter") or a notice of deficiency (a "90-day letter").