Do you anticipate your client to have large balances due on those returns?  Does your client have any foreign-related items such as financial accounts, assets, CFC, trusts, etc. for which information returns would have been required?

If neither of these apply to your client, the IRS would normally settle for 3 to 5 years.  Once you have a better handle of the facts, you could call the PPS with a PoA and discuss the filing with them.

In the event your client has foreign financial assets for which information returns have not been properly filed, you may want to check whether your client is eligible for the streamlined procedures.

Yes, I agree, filing returns that far back is madness.  

As Itonewbie mentioned, I would suggest the IRS be contacted and asked how many returns they want.  From what I've read, they usually only want the last 6 years (or less).

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.  

And, of course, we all know the IRS will not reduce anything to writing for this.

I used to volunteer at a VITA site. It was fairly common for people to come in who hadn't filed in several years. Guidance from IRS was to file returns for the last 6 years. 

Some states are a bit more pushy. Since I have the software back to the stone tablet that recedes the 1040, and I like to punish those idiots that come to me to clean up their act - I file every single one of them. I feel it gives an extra boost to "compliance" and lays out the road of OIC much more cleanly. 

On the other hand I have been told I am a glutton for punishment. 

Start with the newest return first and continue to go back long enough to show a pattern of no balance due.  In my experience six years has been the norm.

I would start with 2019 because if a refund is due, it's not too late to claim it.  (Maybe 2018 if the state has a longer SOL.)  Then get paid for that year before doing 2020, and 2021.  By then you should be able to spot how small these potatoes are.  

I forgot to mention one of the most important issues with late filers.  Get some or all of your fees up front as many of these people have a tendency to disappear when it is time to pay you.

Another Former All Star

Thank you.

Everyone's input was most helpful.

Excellent advice. thanks

All advise is terrific and most helpful

thanks!!!!

MANY THANKS FOR MOST HELPFUL REPLY

EXCELLENT MANY THANKS

GOOD INFO AND QUESTIONS

THANKS

THANKS FOR BRINGING SANITY TO MY MADNESS!!

Noted with thanks!!

Thanks. I'm usually like you. 

thanks!!!

I'd like to thank all of those who replied.

I could have checked at least 3 or 4 of the replies as the solution.

Then more and more very helpful info came in.

So thanks to all of you