This panel will discuss the procedural steps involved in representing taxpayers in deficiency cases from commencement of the examination through trial at Tax Court. Among other things, the panel will address the procedural requirements for seeking the review of the IRS Office of Appeals in both pre-assessment deficiency cases and in collection cases. The panel will also explore the Tax Court requirements for litigating deficiency cases, including jurisdictional and procedural issues. The panel will start at 3:15 pm on Thursday, May 10.