Yes, obviously the settlement reflects analysis by Activision Blizzard, which is exactly the point. The expected outcome of challenging an assessed tax deficit

Yes, obviously the settlement reflects analysis by Activision Blizzard, which is exactly the point. The expected outcome of challenging an assessed tax deficit is part of that analysis, so the choice to settle must be viewed with that in mind. I wish both you and the thread OP would stop comparing this to A) personal (or small business) tax disputes and B) tax disputes that resulted in no additional tax liability. This dispute did result in additional tax liability.