An audit appeal may go to court if little progress can be made through the appeal letter or the letter of protest. An example of which is Raheja v. Commisioner. In this case the appellant was protesting an audit, not on the amount due but on the legality and legitimacy of the audit conducted, which ultimately led to the findings. Audits have been challenged on this ground a number of times, but the taxpayers have continuously been unsuccessful. In this specific case, the Raheja's argued that the Discriminant Function System (DIF) or the Taxpayer Compliance Measurement Program (TCMP) was not used in the selection process of their return, violating their Fifth Amendment right of due process. In addition, the Raheja's claimed that evidence obtained