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IRS.gov Website
Publication 510
taxmap/pubs/p510-053.htm#en_us_publink1000117352

Chapter 15
Examination and
Appeal Procedures(p42)

If 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.