But what of the situation in which a client seeks counseling, rather than presentation of a dispute to a figure authorized to make a decision? In this context, Brad Wendel foregrounds the difficulty that "must be faced in any complex regulatory arena in which a client may seek the assistance of a lawyer to avoid a legal prohibition or penalty through careful planning." As already noted earlier in this series, one of Wendel's targets is abusive tax shelters that are supported by spurious legal advice. In my career as a Dallas practitioner, I saw the collapse of a very fine competitor firm for this very type of conduct and one of its responsible partners sentenced to a lengthy prison stay. In some ways, these cases are easy to analyze in ethical terms ex post facto because they are threaded with bogus transactions. Such is not always the case, though—there are plenty of regulatory regimes in which transactional structures can be manipulated so as to defeat a rule's background justifications.