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If someone is paying a JD, and the JD has given a written opinion backed by E&O, then the JD can eat any and all costs if the item needs to be filed later. For your client, give your opinion as well, documenting the client refused to file the form. I get something similar maybe once a week now (used to be multiple a day) that >2% S Corp shareholder/employees are fine reporting their company paid medical insurance only on a W2, when the las says it is wages (which means it has to be reported on constructive receipt, which is some amount every single paycheck. Similar with the owner/employees who pay themselves randomly, if at all, and not meeting what anyone would consider reasonable wages.

"Coca-Cola said Friday it plans to pay a tax penalty worth $6 billion while it pursues an appeal in a long-running dispute with the Internal Revenue Service. "The company believes it will prevail on appeal," Coca-Cola said of a US tax court ruling dated July 31 that covered the years 2007, 2008 and 2009. The back taxes amount to $2.7 billion, which with interest makes the total owed "approximately $6.0 billion," the company said." "The case dates to 2015 when Coca-Cola received a notice from the IRS contesting the company's accounting of income from foreign affiliates over the need for "arms-length" pricing of transactions with these entities, Coca-Cola said in a securities filing." The big international conglomerates have been very adept at manipulating our tax system for decades Inquiring minds might ask, why does Apple with its Billions of dollars in profits have a US Federal effective tax rate of only 8% ???

Gotta love it when the attorney makes the decision to not file the fiduciary return. And then the client argues with you because "that's what the attorney said." GRRRRR. The estate has over 11K of income!