The risks are high. Take $100,000 to pay for 3 years of filings and find out it takes more. Then what do you do if you don't have an extra $19,000 to finish the audit.
Say good bye to $100,000.
What if you have the money and do not get the audit in the time Welch agreed too? Say good bye to $100,000.
Just consent, get it over with, and audit 2, not 3 years now, for a lesser amount and file a 10-12g on your schedule.