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 O Appealable to the regular division of the U.S. Tax Court. Appealable to the United States Distrct Court if the deficiency is paid. O Appealable to the U.S. Court of Federal Claims if the deficiency is paid. Not appealable.