David Weisbach (Chicago) & Brian Gale (Sidley Austin, Chicago) have published The Regulation of Tax Advice and Tax Advisors, 130 Tax Notes 1279 (Mar. 14, 2011). Here is the abstract:

The rules governing tax advice have been dramatically revised and extended in the last decade. They now have a level of complexity similar to that typically found elsewhere in the tax laws rather than in the broad prescriptions normally found in ethical rules. Many of the rules are intricate and their interactions unintuitive. Tax advisers must be familiar with the details of the rules or risk violations. In this report, Weisbach and Gale survey the rules regulating tax advice and tax advisers and put them in perspective by comparing them with the rules in place in 1990.

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