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I have a client that received a notice of deficiency for her 2004 taxes ... The IRS letter gives her a 90 day window to respond which closed before she came in to our office this year.

That sounds like a statutory notice of deficiency. You might have problems getting anything done at this point without paying the balance due and then requesting a refund on form 1040X. It's too late to fight the issue out in Tax Court, so now it might take an action in circuit court to get things handled.

At a minimum, the IRS is now prepared to do some enforced collection since the 90 days have expired. So your client needs to be made aware that a levy or garnishment can now happen at pretty much any time. Since this is right up Phil's old alley, I'll defer to any comments he may have on this aspect.

However, sometimes just responding with the information they wanted in the first place will take care of things. Just be aware that the IRS has given more than one notice to your client and the collection folks may see her as a bit of a deadbeat for the lack of response to date. Working with a professional can help offset that impression, but you'll need to be ready to follow through quickly on any promises made from this point on. "Underpromise and overdeliver" should be your motto.

--Peter
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