often

No quibble with what you say because you used this qualifier.

My takeaway is that this kind of tactic would be like standard tax attorney manipulation with a family like this, especially in this business. How this whole "I have an excellent tax attorney" thing works. They finagle everything accounting wise in myriad ways similar to this, and then wait and see if the IRS even looks or audits. First and foremost they think: chances are no one will check or audit, which is quite true unless you're not paying anything anywhere. Second, the decision about whether to defend something challenged,  or lay down and say "uncle" and pay the tax and the fine, is simply put off until it is. Because then is the best time to decide whether further attorney's fees are worth the time and effort to challenge back. With the IRS, it often isn't.

This is why he doesn't want his tax returns seen. But it's not like what's going on here is not standard practice for (wealthy) clients of tax lawyers. "Criminal" these two say? Methinks they doth protest too much, they either know that never happens or they are not very good at what they do. Criminal is what the IRS wants the public to think, but they negotiate all these things, they use the "criminal" threat to extort a high payment if they think they can get one when they challenge a filing. This is what tax attorneys do for a living, take care of it and then tell you what you have to pay. Or challenge it for decades if their time would be worth it. (Often when a celeb complains all his money is gone, was mis-managed, is threatened with doing time for non-payment of taxes, they mean they didn't get this kind of advice, didn't have a good tax lawyer doing the "financial planning.")