不公平という指摘もあり

06:13 Aug 29, 2016 

Nope , I was wrong re: 2/ 税理士から traces both points back to the tax agent.
Apologies.

05:50 Aug 29, 2016 

1/ Agreeing all the way with the terms you selected, David ('indicate', and 'inequitable'); finding them consistent with this hired tax agent's need to deal tactfully with his conflict of obligations, namely 'serving his Client's interests' without defaulting on his pledge to his guild or association to abide by their shared 'professional ethics'.

In the circumstance, this means stating the facts as impartially, as a detached observer, avoiding as much as possible terms that would sound openly judgmental (ex. 'not equitable', 'unfair' or 'unjust') and/or loaded with latent/overt emotional connotations that accompany heated debates ('pointing out', etc...)

2/ Now apart from the term variant of 'unjust' that escaped you in this response on the run I would think, using a double passive+infinitive form ('indicated to be') does contribute very well to achieving this flat impersonal tone. The problem, though, is that this introduces an unresolved uncertainty as to the source of that observation: the hired tax agent? of some other source(s)? Don't agree? (but overall, I liked it. Cheers :-))