The warning came after hundreds of ex-players and managers invested in a tax avoidance scheme called Eclipse.
Some face demands of up to £6million each by the end of the year.
Many bills will be up to 20 times higher than amounts invested.
Ex-England boss Sven-Goran Eriksson will also be hit along with former players including Chris Sutton, Duncan Ferguson, Gordon Durie, Nobby Solano, Jussi Jaaskelainen and Graham Kavanagh.
There is no suggestion any of them intended to illegally avoid tax.
Law firm Edwin Coe, hoping to challenge the bills at a tax tribunal, called it a “nightmare scenario”.
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