A good friend of mine went head to head with the Dutch tax service. It was obvious from the start the tax service could never win. So he won...after about 5 years of legal proceedings and having to finance the whole thing up front before getting his money.
Remember you have to fight them in your spare time, for them it's just work time.
In Canada, for example: potential lawsuits must be signed off by a judge who believes the case has merit. This means that you cannot decide to bury someone in legal paperwork simply because you have the money to do so: you must also have a reasonable complaint.
Yes: I skipped over the fact that the US has arrangements with other countries and therefore there are other countries where you can still do this, but the US’s legal system makes it easy.