Audit CAP -- Position Paper and Method of Calculation

[rocknrolls2]

I am representing a client going through Audit CAP. Of course, the 800-pound gorilla in the room is the Maximum Payment Amount and how to calculate it. The IRS agent is asking us to prepare a position paper which sets out a recommendation of the audit CAP sanction amount, which would be a starting point in the negotiation.

Two things:

(1) Does anyone have access to a simple tool to calculate the Maximum Payment Amount that they could with post or provide the web address for?

(2) Can anyone provide a CAP position paper (feel free to redact whatever information or details you consider necessary)?

Either or both of these would be MOST helpful.