While declining to comment on any specific cases, banks or countries, Keneally tickedoff several reasons why a taxpayer might be disqualified from the program after originally being accepted, including a failure to cooperate or a failure to alert the U.S. government (as required by law) that he or she was contesting a foreign summons.
The agent was smart enough to understand, and after a 15-minute hold time (where the minutes ticked by and I wondered if I would be able to make the Allegiant Air flight that was now taking off in 35 minutes), he came back and let me know a manager had approved the changes without any fees.