One major disadvantage the taxpayer has when filing a petition with the Tax Court is that the IRS's proposed tax assessment must be paid prior to trial.

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Taxpayers can dispute the IRS's proposed tax assessment in Tax Court without having to pay the tax in advance. This is one of the unique features of the U.S. Tax Court compared to other federal courts, where payment is typically required before a lawsuit can proceed.

One Major Disadvantage the Taxpayer Has When Filing a Petition