If we're satisfied that we're correct and convincing in our arguments, it's entirely possible that the company will agree that their strategy was aggressive, and they're a company with a philosophy that's a bit risk-aggressive. It's very expensive to litigate cases, for both sides.
Some will be satisfied if John and Fred's area has convincing arguments to support the assessment. Some may file a notice of objection and still deal with Revenue officials and the appeals process. At that point in time, they might be satisfied with the outcome. Very few go off to court. It's quite surprising how few cases go off to court.