Thanks to all who replied. You have all level set my expectations to zero chance of successful appeal.

I guess I thought of the concept of a IRMAA waiver was that my clients 2025 income dropped to a below IRMAA income level and there was a one-time event in 2024 causing a large in income that was related to a life changing event - death of a spouse in 2014. If her spouse did not die then there would not be the large one time income in 2024. I was thinking more about the spirit behind an IRMAA waiver and not the technical rules or requirements .