OK.  I just got off the phone with an officer at IRS appeals.  I submitted a penalty abatement for a client who had fully paid their tax debt in 2007.

It took a year and a half for this case to be reviewed by the appeals office.

It was NOT an easy negotiation, but the IRS agreed to refund my client $99,000.00.    I think that is near my record.

Merry Christmas!