The IRS filed a lien against Joe Francis yesterday, accusing him of failing to pay $33,819,087.14 in taxes for the 2001, 2002, and 2003 tax years.

Joe, who just negotiated a plea bargain to avoid jail time for tax evasion two weeks ago, is insisting that the lien was filed in retaliation for his previous settlement. Joe told TMZ yesterday that he’s now left with no choice other than to file for personal bankruptcy, which he’ll be doing later today.