Taxpayer (a top commercial broker in Orange Country) received a revenue agent’s report assessing tax penalty and interest totaling $247,924 for taxable years and a letter stating that the examiner was going to open two more subsequent tax years which would also be audited. Auditor was sending the taxpayer endless requests for information. The proposed assessments included proposed additional unreported income, passive activity loss limitations, and disallowances of ordinary and necessary business expenses. Taxpayer retained Abajian Law who quickly had the case reassigned and obtained a $43,077 refund for all four tax years and an apology from a new auditor.