Tax litigation basically breaks down into two common categories of tax suits: 1: Deficiency actions and 2. Refund actions. A deficiency action is a lawsuit filed in the U.S. Tax Court to contest a tax deficiency that has been asserted by the IRS. A refund action is a lawsuit filed in the U.S. Court of Federal Claims or federal district court, in which the taxpayer files a legal claim asserting that he or she has overpaid his or her taxes and is thus seeking a refund.
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