Publication 510
taxmap/pubs/p510-055.htm#en_us_publink1000117352If your excise tax return is examined and you disagree with the
findings, you can get information about audit and appeal procedures from
Publication 556, Examination of Returns, Appeal Rights, and Claims for Refund.
An unagreed case involving an excise tax covered in this publication differs
from other tax cases in that you can only contest it in court after payment of
the tax by filing suit for a refund in the United States District Court or the
United States Court of Federal Claims.