The Problem: Regulatory Risk and Operational Complexity
IRS Examination and Audit Response Deadlines
IRS examinations are governed by tight statutory deadlines that, if missed, can permanently waive taxpayer rights. The 30-day letter — the IRS's initial appeals opportunity notice — gives taxpayers 30 days to request Appeals consideration. Missing this deadline waives the right to pre-petition Appeals consideration. The 90-day deficiency notice (statutory notice of deficiency) gives taxpayers 90 days to petition the U.S. Tax Court — missing this deadline permanently forecloses Tax Court review and converts the deficiency to an assessed tax immediately collectible. These deadlines are jurisdictional and cannot be extended by agreement.
FATCA and FBAR: The $100,000+ Penalty Trap
The Foreign Account Tax Compliance Act (FATCA) and the Bank Secrecy Act's FBAR (FinCEN Form 114) requirements impose reporting obligations on U.S. persons with foreign financial accounts. FBAR non-willful violations carry penalties of up to $10,000 per account per year; willful violations carry penalties of the greater of $100,000 or 50% of the account balance per year. In Bittner v. United States (2023), the Supreme Court ruled 5-4 that non-willful FBAR penalties apply per annual report (not per account) — a significant penalty reduction for some taxpayers.
Tax Court Backlog and Stipulated Decision Management
The U.S. Tax Court handles approximately 30,000 new cases annually with a pending docket of 50,000+ cases. Trial sessions are scheduled years in advance in Tax Court cities across the country. Tax practitioners must manage: petition filing deadlines (90 days from notice of deficiency), trial session placement, stipulated decision negotiation, and the complex small tax case vs. regular case procedure election. The IRS Office of Chief Counsel assigns cases to trial counsel only weeks before trial, creating late-stage negotiation opportunities that require immediate response capability.
Claire AI Solution
IRS Response Deadline Management
Claire tracks every IRS notice with its associated response deadline — 30-day letters, 90-day deficiency notices, Collection Due Process hearing requests, Offer in Compromise deadlines — with escalating alerts ensuring no IRS deadline is missed.
FATCA and FBAR Compliance Workflows
Claire manages annual FBAR filing deadlines (April 15, auto-extended to October 15), FATCA Form 8938 preparation, and the Streamlined Filing Compliance Procedures workflow for taxpayers with unreported foreign assets.
Tax Court Petition Preparation and Docket Management
Claire prepares Tax Court petitions from IRS deficiency notices, manages the 90-day filing calendar, coordinates trial session placement, and tracks stipulated decision negotiation timelines for IRS Chief Counsel resolution.
Transfer Pricing and International Tax Documentation
Claire organizes transfer pricing documentation — contemporaneous documentation requirements under Treasury Regulation Section 1.6662-6(d) — and coordinates international information return filing (Forms 5471, 5472, 8858, 8865) with entity structure tracking.
Compliance Checklist
Jurisdictional Tax Court petition deadline tracked from date of deficiency notice issuance — the most critical deadline in tax controversy practice.
IRS examination appeals deadline tracked for every 30-day letter issued — ensuring Appeals consideration is preserved before Tax Court petition rights arise.
Annual FBAR filing calendar managed for all clients with foreign financial accounts — April 15 due date, October 15 automatic extension, with account balance aggregation tracking.
OIC submission deadline tracking, IRS processing timeline monitoring, and 30-day rejection response calendar management for all active OIC matters.
Tax Court trial calendar management — trial session placement requests, continuance motion deadlines, and trial preparation checklist generation.
Annual coordination of foreign entity information returns (5471, 5472, 8858) with entity ownership structure tracking and penalty exposure alerts for missed filings.
30-day CDP hearing request deadline tracked from IRS collection notices — preventing loss of CDP rights and Tax Court collection review.
Form 8857 and equitable relief application deadlines tracked for all potential innocent spouse relief candidates.
Frequently Asked Questions
Never Miss an IRS Deadline or FBAR Filing Again
Claire AI tracks every IRS notice deadline, Tax Court filing, FATCA obligation, and FBAR due date — protecting taxpayers from catastrophic deadline-related penalties.