Clients were under examination and had an undisclosed Swiss Bank account with a high balance of over $2 million and a business venture in another foreign country. Vic was able to work with the Revenue Agent (after several face-to-face meetings) and guide the clients through a successful interview with the Revenue Agent, demonstrating the favorable facts. We were able to successfully submit Form 5471 and Foreign Bank Account Reports (FBARs) to the Internal Revenue Service (IRS) and close the case with zero penalties, although the Revenue Agent initially indicated that a 50% FBAR penalty was appropriate.