Ah, you're right. He can appeal but it doesn't delay the payment process. He's going nuts because no one will lend him money. He says it's an "inconvenience because he has to sell properties". He should never have had that money in the first place! He owes all those back taxes from lying about the value of his properties.

I saw someone describe it like this:

This is like someone who is convicted of fraud complaining that it's an inconvenience to give the money back.