If the Internal Revenue Service was trying to catch the attention of lawyers across the country, it succeeded with a vengeance this month when three New York lawyers pleaded guilty to charges of failing to file federal tax returns.

The three cases are but a preview of things to come. A dozen more lawyers, some from prominent firms, are facing possible criminal charges in New York, according to defense lawyers there. In California, the IRS has three more lawyers in its criminal sights, according to a legal source. In Chicago, one lawyer is under criminal investigation, an IRS spokesman said.

The cases grew out of the IRS's aggressive pursuit of non-filers from all walks of life. As part of the program, the IRS targeted several professions -- all the better to find taxpayers with substantial incomes -- and the agency soon found that law was a fertile hunting ground.

While lawyers on the whole may be no worse than other folks when it comes to failure to file, they should beware. They make juicy targets when the IRS wants to deter tax cheats.

"If you indict a half-dozen plumbers, it's not going to make The Washington Post," said New York defense lawyer Robert S. Fink, who is representing some of the hapless attorneys. "But if you do a half-dozen lawyers from high-profile firms ... they serve a function the IRS wants served."

The New York cases certainly show that non-filers cut across a diverse swatch of the profession. Peter Anderson is a Bronx solo practitioner, whose income was less than $52,000 a year for three of the four years he failed to file, according to court records. Henry J. Clay Jr. is a partner at tiny DeWitt Lockman & DeWitt, a successor to the oldest continuously operating law firm in the nation. His income for the three non-filing years totaled about $500,000, records show. And Howard B. Hornstein, a prominent zoning lawyer at a prestigious Manhattan firm, had total income of more than $900,000 for the three years he failed to file, according to court records.

Hundreds of lawyers have popped up as non-filers since the IRS started running various lawyer lists through its computers seeking matches with tax returns and other records, such as the informational returns filed by partnerships. In northern Illinois, for example, where the IRS began the program last year, the agency has recovered $1.8 million in delinquent taxes from 45 attorneys, according to an IRS spokesman.

The program targeting lawyers appears to have gotten its start in California in 1989, where it quickly was dubbed "Project Esquire." According to a defense lawyer, the IRS agent investigating flamboyant Los Angeles divorce lawyer Marvin Mitchelson, who went to prison last year for tax fraud, concluded that other lawyers might be worth checking out.

The agency initially checked the names of about 44,000 lawyers listed in a California directory against IRS records, according to Houston tax lawyer Larry Campagna. Campagna said he was told by IRS sources that about 4,400 of these lawyers apparently either failed to file returns or to pay the taxes shown on their returns.

Campagna said he was told the IRS moved to collect the back taxes through civil procedures and only those attorneys "who responded negatively were referred for criminal prosecution."

But the New York lawyers faced with criminal charges apparently did not get that chance. An agent from the criminal division "showed up and that was it," said Clay's lawyer, John J. Tigue Jr.

Fink said the IRS has taken a "carrot and stick approach" to lawyers. The carrot is the possibility that "a collection agent shows up and nags you" for the back taxes, handling it as a civil matter, Fink said. And the stick? "You never know if a special {criminal} agent shows up first," he said, and your case lands with federal prosecutors.

Fink says the non-filers are not trying to cheat the government. Tax cheats, he said, hide income or file incorrect returns. Non-filers, particularly lawyers who can easily be traced through partnership returns and other documents, are usually having "emotional difficulties," such as divorces or drinking problems.

Fink acknowledges that there are several "philosophical" reasons why lawyers might be treated differently than other taxpayers: they are officers of the court and are supposed to be guardians of the law.

"The pernicious thing," he asserted, is that the New York lawyers not only are being treated differently than other taxpayers, but differently than other lawyers, who've been given the chance to pay up.

Neither the IRS nor the office of U.S. Attorney Mary Jo White, who prosecuted the cases, was much impressed by that argument.

An IRS spokesman said the agency wants "attorneys and everyone ... to come in voluntarily" if they have failed to file. "For those who don't, we will take compliance action. Some may result in criminal cases. Some may be civil."

Nor were their pleas to misdemeanor charges, and their upcoming sentencings, the last hurdles the three New York lawyers must face. The New York lawyer discipline system undoubtedly will take up their cases. While a few lawyers in egregious tax cases have been disbarred, the most common punishment is a lengthy suspension from practice, said New York tax lawyer Elliot Silverman.

Still, for some, their law firms are their harshest judges. Fink said one client, a lawyer at a prominent Manhattan firm, revealed to his partners that the IRS was pursuing him civilly for failure to file. The firm discharged him. Then, the partners decided that under New York's ethical code they had to notify authorities that he had committed a crime. The lawyer, who settled with the IRS by paying the taxes, then was charged by the state of New York. He pleaded guilty to a misdemeanor, Fink said.

"That's the worst I've heard," Fink said, but few firms show much mercy.

It doesn't have to be that way.

Hornstein's firm, Fischbein Badillo Wagner Itzler, plans to stand by him. "We knew about it before Howard joined the firm" about two years ago, said Richard Fischbein.

He said Hornstein, who'd been with a real estate development company, had suffered "severe business reversals" and "his wife was very sick" during the period of his tax woes. "He told us about it and straightened out his problems," Fischbein said.

Hornstein has had a "distinguished career" as a land-use attorney, Fischbein said. "One mistake does not destroy a life. He ... deserves a second chance here."

But lawyers shouldn't count on second chances. To those who call him each time the issue gets publicity, Fink gives this advice: "Follow through right away, and you will be with the voluntary disclosure program."

Lawyers vs. Tobacco Titans

A group of the nation's top plaintiffs lawyers, never known as a shy bunch, tried out a new weapon this month against the tobacco giants, whom they've sued in a huge class-action case. The lawyers placed a newspaper ad in Winston-Salem, N.C., home to R.J. Reynolds Tobacco Co., offering a reward to former tobacco industry employees for information about tobacco research, the storage of documents and other cigarette-related issues.

Reynolds rushed to court, arguing that the lawyers were enticing ex-employees to violate "confidentiality agreements" with the company and to turn over trade secrets, according to a Reynolds spokesman.

U.S. District Judge William Osteen, of Greensboro, N.C., issued a broad order that temporarily prohibits the plaintiffs lawyers from receiving such information or placing more ads.

"We're not interested in trade secrets," said South Carolina plaintiffs lawyer Ronald L. Motley. "We want to find the skeletons they've buried."

Said D.C. plaintiffs lawyer John P. Coale, "Haven't they heard of the First Amendment in North Carolina?"

The two sides are to meet in court Friday to slug it out over the permanent order Reynolds is seeking.