Client was assessed with a substantial penalty for late filing of Form 3520, Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts. Client received a substantial inheritance that was not reported to the IRS by their tax return preparer, and the nondisclosure was made even worse by the preparer’s inexperienced attempt to come into compliance. The preparer then fumbled the representation before the IRS. We were retained to protest the findings of the revenue agent and request that the penalties be abated. After interviewing the client in detail several times and conducting substantial due diligence, we drafted a persuasive protest to IRS Appeals and resolved the case with a full concession by the IRS with no penalties due.