You jump to that “right wing talking points and smears” almost immediately. It is your default setting. Did your really read the story?
The IRS has made a determination. They have told him how much tax he is required to pay.
Yes, he can appeal it… endlessly. However, appealing a decision says to everyone that he wants to pay LESS taxes. You don’t fight your tax bill if you really want to pay more.
That is the hypocrisy.