This article considers when a taxpayer should not be able to rely on a tax opinion to avoid penalties when the tax … advisor rendering the opinion has an apparent conflict of interest.The article has three parts. The first part describes the … article describes the cases where a taxpayer has sought to rely on the opinion of a tax advisor with a conflict of interest …

on seeing what other agents are doing, corresponding to quasi-moral norms of fairness or reciprocity, and acts whose … performance is conditional on being observed by other agents, corresponding to social norms. The operation of quasi-moral norms is … and generous behavior, but are willing to spend resources on punishing those who do not. Since A's punishment of B may …