I think that what the government is saying is that Doreen has no legal basis for believing that she is filing correct returns, and that while she may still truly believe that she is filing correct, CtC-educated returns, she is legally barred from doing so unless she can enunciate a legal basis for convincing the government otherwise. That's the way that the court system works, my friends; and unless you can set forth a compelling legal argument during your appeal, you are going to lose, no matter how fervently you may believe in CtC or anything else. You may believe that the courts have been consistently wrong on CtC; but unless you can convince them otherwise, you are going to pay the price. Pete did; and it looks like Doreen will do that as well.