I have a potential new client. Foreign owned 1120 (has a vacation home that is never rented - no income for the Corp all those years) - founded in 2000.

Never filed a tax return. 

I know 5472 will trigger 25,000 penalties. But how do I even start. I don't have Proseries from 25 years ago. CORP never had any income. Only asset is a vacation home in Florida. 

Is there any disclosure program available for him?