I have been in contact with an Indian Immigrant living on U.S. shores who has had the unfortunate experience of joining the OVDP to correct past form filing errors. I have been asked to solicit help from any Tax Practitioner or OVDP graduate. She is looking for examples from previous OVDP victims where funds have been excluded from the penalty base. This is to help bolster her argument that the OVDP penalty does not fit the benign failure.