The IRS has recently concluded its audit on Harlan Harvester, an individual, and has made an audit adjustment which will result in Mr. Harvester paying $100,000 in additional taxes if he agrees. He does not believe he owes any additional taxes, but his positions are not clear-cut relative to the Internal Revenue Code and/or recent court cases. He does pass the non-giggle rule in that he can explain his positions without giggling, but his case is intellectually below average. Which Court should Mr. Harvester determine to plead his case?