The New York State Bar Association, a professional organization of which I was a member for many years (I am still admitted to practice in New York, but no longer keep up the association membership), has a detailed letter to the IRS explaining Circular 230 (the IRS answer to litigator's Rule 11 which bans frivilous arguments), a description of how tax opinion specialists have responded to recent changes in these standards, and suggestions for reform. The letter notes that currently overbroad regulations have created a deceptive boilerplate disclaimer culture among professionals who give tax advice. Its predicate explanation of what the circular means is one of the best freely available ones that I have seen.
Basically, the reform recommendations call for narrowing the scope of tax advice subject to special rules designed to stop shoddy opinions designed to protect tax shelter users from penalties since they can argue that they are acting in good faith, while slightly toughening the standards that apply to other kinds of tax advice.
Hat Tip to the Tax Profs Blog.