Ninety-day Letter Law and Legal Definition
Ninety day letter is a formal notice from the Internal Revenue Service (IRS), issued to a taxpayer indicating a tax deficiency. The notice requires a taxpayer’s response within ninety days. A taxpayer receiving a ninety-day letter is entitled to dispute the tax deficiency before a tax court. A ninety day letter is also known as statutory notice of deficiency. A statutory notice of deficiency is issued when a tax payer fails to initiate an appeal procedure after receiving pre action notice form IRS. [26 USCS § 6212, and 26 USCS § 6213]
A ninety day letter also informs the tax payer the result of the audit, the deficiency claimed by the IRS, and the demand for payment. [In re King, 1989 Bankr. LEXIS 1809 (Bankr. M.D. Fla. Jan. 30, 1989)].