Declaratory Action bond anouy for appeal from USTC

Group:

IRS audited clients retirement plan an esop. 

In the USTC declaratory action retirement plan is disqualified. 

Typically on an appeal from USTC the bond amount determined from tax deficiencies. 

However since the Dec action doesn't have a tax deficiency how do you proceed with appeal? 

File a bond with $0?

What companies have you used for appeal bonds? 

Thank you 

Consider asking the IRS’s litigator what appeal bond would be satisfactory to the IRS. Your client might be pleasantly surprised by the answer.