Did the IRS Really Win Case Against UBS?

The IRS settled its summons case against UBS this week and will get account information for fewer than 5,000 Americans with accounts at the Swiss bank. Since the IRS was originally asking for information on 52,000 accounts, is this really the victory the IRS claims it is?

Although the settlement agreement apparently lets the IRS pick which accounts are disclosed (so the IRS won't get information it already has perhaps?) it seems a stretch to think that 45,000 or more secret account holders have come forward under the IRS's "amnesty" program or that the IRS has been able to get that much information from the individuals who have already pleaded guilty ot tax evasion. While the banker has given up a number of names, it is doubtful that he had access to over 45,000 accounts - so what about the other 47,000 tax evaders?

Also, the settlement allows UBS to notify account holders and lets them appeal their account's disclosure to the Swiss government. Are the Swiss using this as a way out?

Meanwhile the attack on offshore accounts continues with more indictments this week.