When cases are not resolved at the IRS Office of Appeals, frequently the only further course of action for taxpayers is to file a Petition in the U.S. Tax Court, or a Complaint in the U.S. Court of Federal Claims, or U.S. District Court. These actions are expensive for taxpayers, since lawyers must spend scores or hundreds of hours gathering evidence, taking depositions, and preparing for trial. Further, taxpayers must spend significant amounts of time over the course of nine to twelve months responding to discovery requests. Make no mistake: federal lawsuits are expensive, time-consuming, and “taxing” on all involved—taxpayers and attorneys alike.