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A taxpayer received a 9 0 - day letter proposing a deficiency. The taxpayer challenged the proposed deficiency in the Small Cases Division of the

A taxpayer received a 90-day letter proposing a deficiency. The taxpayer
challenged the proposed deficiency in the Small Cases Division of the U.S. Tax
Court. If the taxpayer loses the case, then the decision is
Appealable to the U.S. Court of Federal Claims if the deficiency is paid.
Appealable to the regular division of the U.S. Tax Court.
Not appealable.
Appealable to the United States Distrct Court if the deficiency is paid.
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