Reply to IRS penalty- Settle or proceed to litigation?

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[quote=Anonymous][quote=Anonymous]

Broadly, speaking, a second opinion might be in order since you wrote that your advisors had both made mistakes in this matter. I wonder if the way that they proceeded somehow locked you out of proceeding in Tax Court.[/quote]

OP here. Just quoting what a PP mentioned.

I have been wondering about this myself! 
The CPA and the Tax Attorney are from different firms. Their websites state years of experience with international matters. These professionals charge $500+ an hour. I found both of them through my Financial Advisor (who doesn't personally know them but has had clients who have used their firms).

The Tax Attorney was so confident that this was such a straightforward case.  He did mention the IRS bureaucracy and how even he has no idea who actually makes decisions on these cases. That's why he said that if we went to litigation, it will first force the Office of Independent Appeals to provide a justification for their decision, and then the Tax Attorney can build his case around it. But we won't know that justification unless we go through litigation.  [/quote]

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