§ 7206. Fraud and false statements

Any person who —

(2) Aid or assistance

Willfully aids or assists in, or procures, counsels, or advises the preparation or presentation under, or in connection with any matter arising under, the internal revenue laws, of a return, affidavit, claim, or other document, which is fraudulent or is false as to any material matter, whether or not such falsity or fraud is with the knowledge or consent of the person authorized or required to present such return, affidavit, claim, or document;

This is the so-called “tax-preparer” statute, which makes it a crime to willfully aid, assist, procure, counsel or advise in the preparation or presentation of a false return or document.  The statute is often utilized when a return preparer, accountant or attorney assists in the preparation of a false income tax return.