The courts that can address tax matters are the Tax Court, US District Court, and US Court of Federal Claims. This option appears after the receipt of the 90-day letter if the taxpayer does not agree with the decision. For the Tax Court, the taxpayer could choose not to pay the tax and petition in the court. However, the US District Court and US Court of Federal Claims would come into play if the taxpayer's claim for refund with the IRS was denied. One judicial case that was elevated to the US Court of Federal Claims was Dixon v. United States, 1998 U.S. Claims LEXIS 143, 41 Fed. Cl. 467 (Fed. Cl. 1998). In this case, Dixon had their refund denied by the IRS, and when elevated, the US Court of Federal Claims found that Dixon did not provide enough evidence for their claim of overpaying taxes (1)