The TRS may be correct on their findings and the taxpayer may be better off accepting them. If you agree, the case will be closed upon some filing of paper work and payment of the tax. The IRS is willing to settle tax deficiencies more often than people realize. The IRS will lower the amount owed depending on the probability of success on an appeal of the findings. If the IRS determines that they are unlikely to win, they will be very willing to lower the amount due.
Some money is better than no money in their eyes.
Of course the opposite is true if they feel they have a strong case. This procedure is used when the taxpayer is suffering financial difficulty. This is a separate negotiation procedure and will only focus on the taxpayer's ability to pay the tax due. The IRS will then review the offer and answer whether they will accept the proposal. The end result is that the taxpayer and the IRS agrees to a payment plan.