Oh and one more thing, just so I'm sure it's clear what I'm saying.

There is a difference between the court activity that would "appeal"
this order and the court activity that would be used to collect the
fine. They would likely be in different courts at different times.

IF Baxter wants to argue the fine points of Part 97 interpretation and
save his license, he'd better do it as an appeal of the Forfeiture
Order that is started in the 30 day window. If he waits for the debt
collection process to get his arguments before a court it will be too
late for him to keep his license and the lack of appeal to the
Forfeiture Order will be seen as a positive for the FCC. ("Hey, he
didn't object to the order and appeal when he could. Why should we
allow him to debate it now? This is the wrong forum for this debate.")

At the debt collection trial the FCC (Actually the DOJ at this point)
may manage to side step all of the rule violation debates by simply
saying that Baxter has already refused to avail himself of the proper
appeal process so his arguments are not valid in the debt collection
phase. I suppose that in an effort to be totally fair the judge over
the debt collection case will allow a limited debate of the facts
related to the Forfeiture Order but I doubt it will be allowed to go on
very long and I'm sure the judge will be keeping the arguments under
control.

Ever been to traffic court? Let's say you get a ticket for running a
red light and you and the officer stand before the judge. The Officer
says you did it, you say you didn't. Who is the judge going to
believe? It won't be you. the Judge will patiently listen to all you
have to say that is even remotely relevant, and render a judgment
against you. That is of course if you don't come up with some hard
verifiable evidence to show what the Officer is saying is not true.

He has no hard evidence so Baxter will end up the same way.