AFAIK the IRS has historically been more, er, disinterestedly nitpicky as opposed to disproportionately vindictive. More "you say X we say Y here's your option

AFAIK the IRS has historically been more, er, disinterestedly nitpicky as opposed to disproportionately vindictive. More "you say X we say Y here's your options you are Z days over with a W% rate", rather than "Ah hah! $50 dollars error, time to make an example outta this poor bastard."