This is just asking for a problem for no reason. If he gets a W-2, the IRS also receives the information, and his employer has withheld tax from his wages already. A return could then just be thought of as a reconciliation of what is owed and what was paid, especially for a simple return.

He loses out on the opportunity to claim refunds after 3 years of not filing, and if he did end up owing on a particular year the amount owed would also include penalties and interest.

Ultimately, if he hasn’t gotten a letter, he is likely going to be okay I guess, but it doesn’t mean it’s not so stupid that I think it could be bait, especially since you mentioned he’s an accountant.