Taxpayers had undisclosed foreign accounts (including those in Russia) that contained over $ 1 million. At the time, the only option was an OVDP and thus, the taxpayers decided to proceed on that basis. Vic worked with the taxpayers and their CPA and conducted an extensive investigation into the facts, including interviews with the prior tax return preparers and financial advisors. Vic crafted a detailed and persuasive nonwillful penalty memo which was accepted by the IRS so that the penalty on high balance was reduced from 27.5% to 5%. Vic, however, recommended that the taxpayer “opt out” of the OVDP and pursue a 0% penalty, executed a well-reasoned strategy and was successful. Vic convinced the IRS to accept a 0% penalty which saved the taxpayers hundreds of thousands of dollars.