The IRS recently audited Johnson Corporations (a C Corporation) 2015 federal income tax return. The Revenue Agent disallowed most meals and entertainment expenses the corporation deducted on the grounds that the expenses had no business purpose. Recently, Johnson Corporation received a copy of the Revenue Agent's Report (RAR), along with the 30-day letter, which showed additional income tax due of $65,000, plus interest and penalties. The president of Johnson Corporation, Jeremy Johnson, strongly disagrees with the RAR and has vowed to "fight all the way to the Supreme Court if necessary." He would like you to:

A. outline all the options he has in dealing with the Internal Revenue Service and/or litigating the matter in court; and

B. advise him regarding which option(s) he should use.