 Solution

Suppose that the countable ordinal $\alpha$ satisfied $V_{\alpha }\models \mathsf{ZFC}$. The axioms force $\alpha$ to be a limit ordinal above $\omega$, so choose an externally countable cofinal function $n\mapsto {\alpha }_n$ into $\alpha$, with ${\alpha }_n+1<\alpha$. The internal Axiom of choice gives a bijection in $V_{\alpha }$ between each $V_{{\alpha }_n}$ and some ordinal below $\alpha$. Every such ordinal is externally a countable set, hence every $V_{{\alpha }_n}$ is externally countable. The countable union of countable sets is countable, sowould be countable. But $V_{\alpha }$ contains the full power set $\mathcal{P}(\omega )$, which is uncountable by Cantor theorem. This contradiction is the result Countable rank-initial segment cannot model ZFC, and therefore