The IRS recently announced a program to lure holders of stealth offshore bank accounts to come forward, bare their assets and cough up six years of back taxes, interest and penalties. Will it succeed? It likely will not attract a significant number of eligible taxpayers. And if it doesn't, the IRS will likely not be able to deal with 52,000 UBS tax scofflaws, not to mention all the others. Also, the IRS shouldn't proceed unilaterally. There should be parallel diplomatic intervention by the Swiss government.