Former Jenkens & Gilchrist tax lawyer Donna Guerin folded her cards Sept. 13 and pleaded guilty to helping wealthy clients cheat the Internal Revenue Service out of hundreds of millions of dollars through illegal tax shelters.

Just three months after Southern District Judge William Pauley granted a new trial to Guerin and two codefendants because of juror misconduct, Guerin admitted to issuing opinion letters intended to protect clients from IRS scrutiny by attesting that the complex transactions at issue had economic substance.