A taxpayer must pay any tax deficiency assessed by the IRS and sue for a refund to bring suit in the U.S.District Court. Only in the Tax Court can jurisdiction be obtained without first paying the assessed tax deficiency.

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In the U.S. District Court, a taxpayer must pay the assessed tax deficiency and then sue for a refund. The Tax Court allows taxpayers to dispute a deficiency before paying it.

A Taxpayer Must Pay Any Tax Deficiency Assessed by the IRS