[broiler]

I can tell you from being in tax court (as a CPA) that the process is more like arbitration. Each side explains their point and the judge comes up with a decision. The difference here is that the IRS assessment stands until they lose, which is why most people look at it as a guilty until proven innocent situation.

Tax court is not a taxpayer friendly place since you will find that most judges are former IRS attorneys or Department of Justice tax attorneys. The reason for this is that a good tax defense attorney would not take the substantial cut in pay to become a tax court judge.