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James, this has the potential to be a great case or it could be a nightmare. So here is what I would do:
1. With the client, explain that the assessment could be challenged if the records were reviewed. Does she even have access to the records, does she know what happened during the exam, and is she willing to pay to have the work done?
2. Do the Offer/RCP analysis and see if an Offer is even a possibility.
3. Go through with her in detail who did what, are their former employees who are witnesses to back her story up, any evidence she didnt sign checks, etc…. Where we are going here is whether she has an innocent spouse case.
I think you need to figure out if she is or could be an Offer candidate, does she have an innocent spouse argument, and are there records/is she willing to spend the time and money to fight the assessment.