---
title: "Assess a tax practitioner's exposure under Circular 230"
url: "https://ailawframework.com/practice/professional-discipline-and-occupational-regulation/assess-a-tax-practitioner-s-exposure-under-the-expanded-sanctions-regime/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A63-H20261018-6-US"
practice_area: "Professional Discipline & Occupational Regulation"
tier: "yellow"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# Assess a tax practitioner's exposure under Circular 230

> List each IRS filing or representation in the file, the statement made to the IRS or the client, and the source the practitioner relied on. Do not grade the conduct.

Canonical page: https://ailawframework.com/practice/professional-discipline-and-occupational-regulation/assess-a-tax-practitioner-s-exposure-under-the-expanded-sanctions-regime/united-states  
Last reviewed: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Professional Discipline & Occupational Regulation](https://ailawframework.com/practice/professional-discipline-and-occupational-regulation.md) |
| Human involvement | Yellow: Lawyer and AI draft together |
| How AI is used | List each IRS filing or representation in the file, the statement made to the IRS or the client, and the source the practitioner relied on. Do not grade the conduct. |
| What the lawyer must review | The IRS Office of Professional Responsibility investigates and disciplines violations of Circular 230, which governs practice before the IRS by attorneys, certified public accountants and enrolled agents, and also covers appraisers and Annual Filing Season Program return preparers. Section 10.22 (31 CFR § 10.22) requires a practitioner to exercise due diligence in preparing, approving and filing tax returns and other papers relating to IRS matters, and in determining the correctness of oral or written representations to the Treasury and to clients about any matter the IRS administers. A practitioner is presumed to have exercised due diligence when relying on another person's work product if the practitioner used reasonable care in engaging, supervising, training and evaluating that person, except as §§ 10.34 and 10.37 modify that presumption. Section 10.50 authorises censure, suspension or disbarment after notice and an opportunity for a proceeding if the practitioner is incompetent or disreputable within § 10.51, fails to comply with Circular 230 under the § 10.52 standards, or with intent to defraud wilfully and knowingly misleads or threatens a client. A monetary penalty may not exceed the gross income derived, or to be derived, from the conduct. You decide the exposure. Do not treat a generated summary as the diligence § 10.22 requires. |
| Written for | United States |
| Applies to | [Assess a tax practitioner's exposure under the expanded sanctions regime](https://ailawframework.com/practice/professional-discipline-and-occupational-regulation/assess-a-tax-practitioner-s-exposure-under-the-expanded-sanctions-regime.md) |

## Checking plan

- What the AI does: List each IRS filing or representation in the file, the statement made to the IRS or the client, and the source the practitioner relied on. Do not grade the conduct.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- Section 10.51 (incompetence and disreputable conduct) and §§ 10.34 and 10.37 were not opened. Do not list prohibited acts from memory.
- The IRS page links a Circular 230 PDF marked 0614. Confirm it is the current compilation before quoting a section that may have moved.
- State bar discipline can run at the same time. Circular 230 does not displace Model Rule 8.5.

## Sources

- [31 CFR § 10.22, diligence as to accuracy (Circular 230)](https://www.law.cornell.edu/cfr/text/31/10.22) (checked 2026-10-22)
- [31 CFR § 10.50, sanctions (Circular 230)](https://www.law.cornell.edu/cfr/text/31/10.50) (checked 2026-10-22)
- [IRS: Office of Professional Responsibility and Circular 230](https://www.irs.gov/tax-professionals/office-of-professional-responsibility-and-circular-230) (checked 2026-10-22)

## Forms and precedents for this task

| Form or precedent | Kind | AI level | Summary |
| --- | --- | --- | --- |
| [Tax practitioner Code breach and sanctions map (Tax Agent Services Act 2009)](https://ailawframework.com/precedents/professional-discipline-and-occupational-regulation/tax-practitioner-code-and-sanctions-map.md) | Checklist | Yellow | Map of a possible Code breach by a registered tax agent or BAS agent against the Code items, the 2024 Determination, the Board's sanctions, and the 30-day notification duties. |

Signed-in accounts can read the full text of each one.

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*