My wife filed an OVDP with the Opt-Out provision because she wasn't aware of receiving an inheritance until communication with a different foreign bank. I am a CPA and after us discovering an account, I immediately filed all of the amended returns, 3520 and FBAR and hired an OVDP specialist attorney. All audits were clean in all tax years and IRS field agents agreed with our position in the Opt-Out. The IRS asked for bank documents, so I contacted the bank and got a form signed by my wife to open a bank account that she didn't know she signed and thought she was signing estate papers for selling her deceased mother's home and other power of attorney papers for her sister. There was no money in this account and no obligation to file anything. I'm a CPA and I estimated that the estate would take at least 3 years to wind down for estate funds to be distributed (similar to US), but Belgium has different laws and her sister put funds into her account without our knowledge. The IRS denied our Opt-Out because of this piece of paper and where the IRS assumed that the account was funded at that time and would not grant us a consultation. Now, it requires suing the IRS in District Court and I'm looking for an attorney experienced in OVDP who has practiced in District Court against the IRS. I am confident it will not go to trial once an IRS attorney decision maker reviews these facts.