2. Following an audit of his 20X1 income tax return, the IRS assessed Charlie Cheapskate as a result of the disallowance of certain deductions. In addition to the tax, the IRS assessed interest and a negligence penalty. Charlie wishes to dispute the propriety of this assessment and he con- sults you regarding the most economical way in which to do it. He has heard that the deduction challenged has been consistently allowed by the Court of Federal Claims and consistently disallowed by the Tax Court. Charlie tells you that he only has enough money to pay the tax. He cannot pay the interest and penalty. Charlie wants to know whether he can take his case to the Court of Federal Claims