What is the typical path from a taxpayer protest to litigation?

• A. After protest, a case goes directly to the Tax Court.
• B. The protest is settled automatically with no further action.
• C. The protest is followed by a conference or Appeals review, and may escalate to litigation if unresolved.
• D. Protests are decided only by the district court.

Answer: (C)

The main idea is that after a taxpayer files a protest, the usual path is an administrative review by the IRS Office of Appeals. This review typically begins with a conference where the taxpayer and an Appeals officer discuss the issues, look at the evidence, and try to settle the dispute without going to court. If no agreement is reached, the case can then move to litigation, most often in the U.S. Tax Court, with the District Court as another potential venue for certain types of cases. So the protest isn’t automatically settled or sent straight to court; the Appeals review is the normal next step, and litigation is a possible escalation if unresolved.