The big factor then during appeals would be interest continuing to accrue if the debt is not paid off. Probably the amount not in dispute would get paid right away after the ruling, but if the amount in dispute is large that does not help very much in reducing interest accumulation. Or maybe the amount in dispute gets held in some sort of escrow account. If interest accumulation could be stopped while appeals are in progress that would be a big help, but don't know if that would be how it would work.
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