Ronaldo LeChump, who currently lives in Florida and is finalizing a bankruptcy. He paid only $750 whole dollars in Federal income tax in 2019. He paid another $500 dollars in federal income tax in 2020. After a contentious IRS audit, the IRS assess Ronaldo the Chump a tax due of $11,750,000 for 2019 and $21,875,00 for 2020. How should Ronaldo the Chump proceed?

a) Do not pay the liability and sue the IRS in US Tax Court.

b) Do not pay the liability and sue the IRS in US Federal Court of Claims

c) Pay the liability and sue the IRS in 10^th US District Court

d) Pay the liability and sue the IRS in Federal Circuit Court of Appeals