If the taxpayer does not respond to a thirty-day letter within the time set, the Service will issue a statutory notice of deficiency. The taxpayer has 90 days (150 days if the notice is mailed to a person outside of the United States and the District of Columbia) to file a petition with the United States Tax Court for a redetermination of the deficiency.
In addition, a foundation may contest the additional tax in the United States District Court or in the United States Court of Claims if the initial tax is paid. The additional tax does not have to be paid.
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