About the appeals going on forever, could happen but it looks to me like a settlement happens before an appeal is make.
Quote:
District Court and Court of
Federal Claims
If your claim is for a refund of any type of tax,
you may take your case to your United States
District Court or to the United States Court of
Federal Claims. Certain types of cases, such as
those involving some employment tax issues or
manufacturers’ excise taxes, can be heard only
by these courts.
Generally, your District Court and the Court of
Federal Claims hear tax cases only after you have
paid the tax and filed a claim for refund with the
IRS. You can get information about procedures
for filing suit in either court by contacting the
Clerk of your District Court or the Clerk of the
Court of Federal Claims.
If you file a formal refund claim with the IRS, and
we haven’t responded to you on your claim within
6 months from the date you filed it, you may file
suit for a refund immediately in your District Court
or the Court of Federal Claims. If we send you a
letter that proposes disallowing or disallows your
claim, you may request Appeals review of the
disallowance. If you wish to file a refund suit,
you must file your suit no later than 2 years
from the date of our notice of claim disallowance
letter.
Note: Appeals review of a disallowed claim
doesn’t extend the 2 year period for filing
suit. However, it may be extended by
mutual agreement.
|
http://www.irs.gov/pub/irs-pdf/p5.pdf