Jay A. Soled (Rutgers, Business School) has published Third-Party Civil Tax Penalties and Professional Standards, 2004 Wis. L. Rev. 1611.  Here is the Conclusion:

Tax return preparation is anything but a solitary act. It usually involves a coterie of accountants, lawyers, banks, brokerage houses, employers, and charities, as well as a myriad of other players, each with a civic responsibility to help foster–or at least not undermine–tax compliance.

Yet, as evidenced by this analysis, these players are failing miserably in the fulfillment of this civic responsibility. Why? A chief reason is that the third-party civil tax penalty structure is in such disarray. It is poorly organized, ineffective, and unfair; there are few redeeming qualities about it. Reforming the third-party civil penalty structure to mirror the three-tier civil tax penalty structure that applies to all taxpayers would go a long way toward its improvement and, hopefully, overall tax compliance. Both the ABA and the AICPA should follow suit and implement tougher professional standards, and institute measures to ensure that these tougher standards are enforced.

Congress can go, and has gone, to great lengths to protect its coffers against outright thieves and robbers. Likewise, professional boards can exercise and, on occasion, have exercised, their muscle and removed the professional licenses of those members who act egregiously and regularly transgress ethical boundaries. Nevertheless, fiscal protection requires more than token symbolism–Congress and professional boards must institute sweeping reform measures. Congress’s failure to do so may result in them sharing the fate of the "wooden-home owner," who has a sophisticated perimeter security system designed to keep common criminals and trespassers at bay, but neglects the infestation of thousands of termites that lie barely hidden, causing tremendous structural damage to his home.