@sjrcpa   No, but I never file Forms 3115 either, and so far I have managed to avoid Leavenworth. 

My client who is a professional fiduciary files them for every case (conservatorships, estates and trustee appointments) and I understand that's SOP for those licensed in that profession.  

They tell me it does result in IRS sending notices concerning 1040 and 1041 filings to the fiduciary.  This is often helpful if they get a case where they don't know if returns have been filed, or taxes owed.  

Do a search for Internal Revenue Manual 3.13.5.32 for details on what IRS does with these. Apparently they also ask for a Form 8822 with them. I don’t know if that’s what my client does.

There’s this interesting detail in the Manual:

“When reviewing Form 56, if you notice the taxpayer is appointing a high ranking IRS or Treasury employee or other high ranking governmental official or him/herself as a fiduciary, refer these cases to Frivolous Return Program (FRP). See IRM 3.13.5.7 for additional guidance.”