Seven Prince George's County police officers who became ministers in the Universal Life Church to reduce their taxes have filed a multimillion dollar malpractice suit against their former lawyer, charging that he failed to warn them the plan might expose them to criminal prosecution.

In the $32 million suit filed Friday in Prince George's County Circuit Court, seven county police officers and their wives allege that they consulted lawyer Robert S. Hoyert of Lanham for advice about the legality of a tax avoidance plan in which they were ordained as ministers in the Universal Life Church of Modesto, Calif., deposited money in an account under the church's name, used the funds to pay personal expenses, and then deducted the money from their taxes as charitable contributions.

At a 1982 meeting, the suit says, the officers "expressed to Hoyert their concern that they did not want to pursue the Universal Life Church tax deduction if there was any possiblity that a criminal investigation would result because a negative impact of their careers as police officers would be likely to result."

Hoyert assured them that no criminal sanctions would ensue, and that the only possible federal or state penalties would be civil, according to the suit.

However, one of the officers, Robert F. Fowler of Upper Marlboro, was indicted by an Anne Arundel County grand jury last year on 18 tax charges. He eventually received probation before judgment on the condition that he perform community service.

Fowler also was subjected to departmental disciplinary proceedings in which he was ordered to pay a $100 fine, according to David Whitworth, the lawyer who filed the malpractice suit.

The other officers -- Mark Brubaker and Richard Ratliffe of Upper Marlboro, Donald Knepp and John Luskey of Clinton, Gerald Howard of Camp Springs and George Collins of Glenn Dale -- also allege that their careers have been hampered as a result of Hoyert's advice.

Whitworth said none of the officers has been promoted since the controversy.

The suit, which also names Hoyert's partner, William L. Yoho and their firm, Hoyert & Yoho, further charges fraudulent billing practices and intentional infliction of emotional distress.

Hoyert said he had not yet seen the suit and could not comment. Yoho could not be reached for comment yesterday.