BMK recently assisted a client who was a self-employed businessman that was assessed approximately $2 million of additional taxes and penalties over three tax years. We filed a protest of the 30-day letter and requested that the case be referred to the appeals branch in the Boston office. After 16 months, the IRS ultimately agreed and closed the case seeking a deficiency of less than $5,000 for the same three year period. This case was a stark example of an overzealous revenue agent who did not understand business and pursued erroneous claims against a tax payer who was the son of a businessman audited by the same revenue agent. We represented the father in tax court litigation against findings by the same revenue agent and again resolved the matter for a small fraction of the amount originally assessed during the audit.