Discuss which penalties, if any, the tax adviser might be charged with in each of the following independent circumstances. In this regard, assume that the tax adviser:
a. Suggested that the client invest in a real estate tax shelter.
b. Provided a statement of assurance as to the accuracy of the financial data that are included in the prospectus of a real estate tax shelter.
c. Suggested to the promoters of a real estate tax shelter that a specific accounting technique, not recognized by generally accepted accounting principles, should be used to construct the prospectus.
d. Failed, because of pressing time conflicts, to conduct the usual review of the client’s tax return. The IRS discovered that the return included fraudulent data.
e. Failed, because of pressing time conflicts, to conduct the usual review of the client’s tax return. The IRS discovered a mathematical error in the computation of the taxpayer’s standard deduction.