We are in agreement. The IRS may actually have no basis whatsoever for the assessment. Of course they don't need one. But then one cannot use that as a rationale to prove one thing or another.Asking anyone to describe the rationale behind any action of the IRS is tantamount to asking for proof of the existance of God. I may be able to give a philosophical argument proving the existance of God, but at the end, we'd have both wasted our time. Same would go for the IRS. IRS does what the IRS wants for the most part.