Rowanda could not settle with the IRS at the appeals conference. If she wants to litigate the issue but does not have sufficient funds to pay the proposed tax deficiency, Rowanda should litigate in the:
A. U.S. District Court.
B. U.S. Circuit Court of Appeals.
C. U.S. Court of Federal Claims.
D. U.S. Tax Court.
E. None of these.
Answer: D. U.S. Tax Court.