Sam has just completed an IRS audit. The examination noted a business transaction that Sam and the IRS audit could not agree. Sam has completed the dispute resolution process and still disagrees with the IRSs position on the find. Sams lawyer is under the opinion that a jury would be sympathetic to her position. Sam has the means and ability to pay the note deficiency but would like the courts to provide an opinion on the matter. Sam would like to option of appealing any lower courts unfavorable decision. Which court is most appropriate for sam?

• U.S. Tax Court: Small Claims Division
• U.S. Court of Federal Claims
• U.S. District Court
• U.S. Tax Court