Sure, there can be returns on debt restructuring...with the right parties. I highly doubt the IRS is going to settle for 10% or even 30%. And, that $1 million IRS levy was before B&L's compensation for 2012. Also, don't forget about that former noteholder. He could take AAPT back to court and force B&L to give him half the shares in the company. That was the original deal he had with them. Or he could file the stipulated settlement, and there isn't a think AAPT could do about it.
There are so many others who will come of the woodwork. I don't see how or why a restructuring is even being considered.