See Special Enrollment Exam Quiz
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SEE PART 3: REPRESENTATION, PRACTICES, AND PROCEDURES
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A taxpayer's 2022 return was examined after she moved to another state. She never notified the IRS of her new address and filed no later return showing it, so the IRS mailed the examination notices and a statutory notice of deficiency to the address on her 2022 return. She never received them, did not petition the Tax Court, and the IRS assessed the deficiency in April 2024. In November 2025, she receives a balance-due notice and has not paid the assessment. She shows her enrolled agent a bank statement proving that the deposit the examiner treated as unreported income was a nontaxable gift from a family member. She asks how to challenge the assessment.
Which of the following is the correct advice regarding the taxpayer's ability to challenge the assessment?
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