Herbert N. Beller (Sutherland Asbill & Brennan, Washington, D.C.) has published The New Penalty Regime: Proceed With Caution!, 106 Tax Notes 311 (2005) (also available on the Tax Analysts web site as Doc 2004-23791, 2005 TNT 12-30).  Here is the abstract:

This Special Report reviews recently enacted penalties and related statutory provisions and administrative requirements designed to strengthen the government’s hand in its battle against abusive tax shelter transactions, particularly when required disclosure of those transactions is not made. Beller demonstrates that the new rules directly affect both the taxpayers and their advisers, and could in some instances result in significant changes in the nature and scope of the professional relationship between tax practitioners and their clients.