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Wesley Snipes has been fighting the government for years to keep the IRS from collecting $23.5 million in back taxes.

According to Yahoo, the “Blade” star offered to settle his debt for nearly $850,000, but the IRS rejected, so he filed a petition asking the tax court to overturn the decision.

On Thursday, U.S. Tax Court Judge Kathleen Kerrigan upheld the government’s decision, per the Hollywood Reporter, after Snipes failed to convince a tax court that he doesn’t have the assets to pay more than six figures.

In making her decision, Judge Kerrigan said, “Given the disparity between petitioner’s $842,061 OIC [offer-in-compromise] and the settlement officer’s calculation of $9,581,027 as his RCP [reasonable collection potential], as well as petitioner’s inability to credibly document his assets, the settlement officer and her manager had ample justification to reject the offer.”

The judge also determined that paying the $9.5 million would not leave the actor in economic hardship.

In 2008, Snipes was sentenced to three years in prison for not filing his federal income tax returns.