Charles A. Rose (J.D. 2011, Columbia) has published The Tax Lawyer’s Dilemma: Recent Developments Heighten Tax Lawyer Responsibilities and Liabilities, 2011 Colum. Bus. L. Rev. 258. Here is part of the Introduction:

This Note argues that the burdens of heightened liability and increasing uncertainty undermine the ability of tax lawyers to add value through viable tax advisory services, and that the rules and standards governing tax opinions should be revised to encourage lawyers to give legitimate tax advice, rather than driving lawyers away from the practice altogether. Part II provides a brief overview of the wide variety of services provided by tax lawyers, and examines the purpose and function of tax opinions. Part III documents the rise of the tax shelter market and the role of lawyers in the tax shelter industry. Part IV examines the judicial and legislative responses to tax shelters, and considers how the developments in the law have affected tax lawyers as a profession. Part V explores the dilemma currently facing lawyers engaged in legitimate tax practice and analyzes recent efforts to improve the tax system. This section proceeds with a critique of the recent developments and proposed changes before offering an alternative solution. Part VI concludes.