Prohibited Transaction: Can 4975(a) tax be reduced

In reliance on advice of prior counsel, a client engaged in what has turned out to be multiple prohibited transactions, with a 4975(a) tax due of around $200,000.  Client has corrected the prohibited transactions, so no second-tier tax is involved.

          First Question: Does the IRS have any discretion to not assess the full 4975(a) tax? 

I know the IRS has discretion not to assess a second-tier tax, and discretion not to assess penalties for failing to file 5330s under IRC 6651(a). I know the client can apply for an individual exemption with the DOL, and that the DOL has the discretion to reduce penalties under ERISA Section 502(l)(3) for reasonable cause.

          Second question: Is there any IRS discretion or other statutory or regulatory basis to reduce the 4975(a) tax?  What are the client's options if the $200,000 tax would be an extreme hardship on the taxpayer by using up essentially all of their savings and other assets?

Thanks for any help. Feel free to email separately if you prefer: jkirtner@hershnerhunter.com