And who would you contact at IRS?  (Not that anyone answers the phone.)  And do you really expect something in writing?  (Perhaps delivered by a flying pig.)  The revised Internal Revenue Manual indicates that voluntary disclosure may help if the taxpayer is trying to avoid criminal prosecution, but we know far too little to hazard a guess about this practitioner's client.  Would refunds have been paid on timely returns?  Would the balance due be three figures or six figures for most years?  Let's not pull out an AK-47 if a flyswatter would work.  Even if we want to show off our skills with a big gun.