Regulation of Tax Practice
The point of conflicts of interest rules is to protect clients' reasonable expectations that legal advisors and representatives will act on their behalf free from compromising loyalties and influences. Thus, the basic principle embodied in the Model Rules' conflict provisions is that a lawyer may not represent anyone where the interests of another person - a current or former client, perhaps, or the lawyer's own interests - could impair the lawyer's ability to zealously and impartially act on a client's behalf. Resolution of a conflict might entail declining to undertake representation, withdrawing from an existing representation, or obtaining a Client or clients' written consent to proceed despite a conflict.
Linda Galler and Michael B. Lang,
Transactional Planning and Advice Regulation of Tax Practice
Available at: http://scholarlycommons.law.hofstra.edu/faculty_scholarship/798