The first two of my buds that it happened to had to fight it with the IRS, and won. They had little to no overwater time, but the IRS sent them a nastygram stating they had to prove it.

I was dash 3 in the fight. I xeroxed my logbooks, highlighted the flights that had any overwater time, and calculated how much was overwater. For me it was about 7 pct of my flight time. They accepted this and I didn't have to have a meeting with them. What a relief.

Knowing this now, it will definitely affect my choice of my next contract job.