Joint return?  What is the widow's excuse for overlooking it? She didn't know about the income, just signed the return like she always did?  It's unfortunate that she paid it first and now wants to question it afterwards.  You should check that the supervisory approval requirements were met.  This sounds like a CP-2000 case where IRS will argue it was untouched by human hands -- but will admit that every return is reviewed by human eyes. I had one case where the supervisor just checked a box but did not indicate approval. Settled it on other grounds.