Eddie doesn't really have the money to pay the assessment from the IRS but he feels the IRS and the Appeals Officer got it wrong in their examination and subsequent appeal. The assessment is significant in amount and may be large enough to justify the costs of defense. Eddie really thinks he has a chance to win if just someone who was knowledgeable in the law heard his case. Eddie should pursue his case in The SCOTUS The Federal District Court. Eddie is an idiot and should drop the case if he didn't win in appeals. The US Tax Court The Court of Federal Claims