First I would check whether the IRS "first time abatement" policy applies to corporate returns.  If not, I would ask for abatement based on "reasonable cause."  Haven't seen any of those recently, but it used to be that IRS would agree when you least expected it, and deny when it seemed like a sure thing.  

Don't most E&O policies have a deductible of at least $1,000?  Probably more, these days.