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Paula, a resident of Los Angeles, could not reach an agreement with the IRS at...

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Accounting

Paula, a resident of Los Angeles, could not reach an agreement with the IRS at her appeals conference and has just received a 90-day letter with a $85,000 tax deficiency notice. If she wants to litigate the issue but does not have sufficient cash to pay the proposed deficiency, what is her best court choice?
U.S. Tax Court
U.S. Federal District Court
U.S. Court of Appeals for the 9th Circuit
Small Claims Division of the Tax Court
Los Angeles Superior Court

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