Ya think? In any such case there will be a winner and loser.

Meet and negotiate a lump sum amount to pay the IRS settling all outstanding issues up through the current date and attempt to get a 24 to 36 month pay plan or a reduction for paying all of it at one time.

Based on what Gomsak said at prior meetings, negotiation was over when OPA appealed the tax court decision. IRS might agree to some payment plan but with interest, and likely no reduction in total tax. IRS won; it has no reason to negotiate what OPA owes the government.

Take money from reserves and pay the bill

I expect that to happen rather quickly.

Given a reading of the original ruling this is not necessarily a surprise.

Well, if it was that clear cut to you at the time of the original tax court ruling, did you ever suggest to the board that it drop the case and not spend about $60,000 on the appeal?