My client withdrew a large amount of his retirement resulting in his taxable income being taxed at a much higher rate (24% vs.10%). The reason he withdrew was due to hardship his family was experiencing. He did not have any knowledge or idea of the repercussions and only requested 20% to be withheld. He now owes $82,000+ in addition to what was already paid in 2023. This does not include the tax due for the state. 

Reflecting on anyone's experience, would my client's situation be a legitimate reason that the IRS would honor an abatement request upon filing Form 843?

Thank you in advance for any advice or information.