Wow. That was harsh. The husband was the only owner of the business.  Can you please point me to something I can reassure the widow on?  Her neighbor was caught in the same situation with another CPA  firm and their conclusion was no recapture was required. That was one year ago. She wants me to cite what I’m relying on if there is no recapture so she can try to rest at night. Her neighbor paid a penalty for asserting there was no recapture. She told me it’s hard enough to be a widow and she doesn’t want to battle the unlimited budget of the IRS.