All in just for the mileage it is a $50k adjustment. Some of it warranted because the client did not have maintenance records to support the miles taken. This is on top of the threat to disallow all credit card charges (another $45k) because they commingled personal charges (that were not expensed) and disallowing 50% of the charges for shareholder cellular devices. And he has already opened 2018.
Something beats nothing, but I would much rather go to appeals with $50K of mileage than -0-.