If MS come up with significant technicalities or challenges to the amount due, the IRS will have to choose between litigating each one of them, which both costs them money and involves the risk of losing in court, or coming to an out-of-court agreement with MS.
Obviously if MS don't have anything that won't get laughed out of court, they shouldn't get much of a reduction. If your challenge to your tax bill doesn't involve anything where the rules are hard to interpret and precedent has not been set, you also won't. (If it does, your tax affairs are probably much more complicated than the average citizen. Which is obviously true for Microsoft.)
Worth bearing in mind too that the number might be an optimistic headline figure which has been rounded up in various ways by the IRS, to make themselves look tough, and to encourage MS to settle.