---
title: "Build a tax due-diligence issues list from the data room"
url: "https://ailawframework.com/practice/taxation/build-a-tax-due-diligence-issues-list-from-the-data-room/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A26-T1-R13-US"
practice_area: "Taxation"
tier: "yellow"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# Build a tax due-diligence issues list from the data room

> List documents that bear on the questions the lawyer supplies, and flag a question with no document. Do not state whether a tax position is correct.

Canonical page: https://ailawframework.com/practice/taxation/build-a-tax-due-diligence-issues-list-from-the-data-room/united-states  
Last reviewed: 2026-10-22

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

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Taxation](https://ailawframework.com/practice/taxation.md) |
| Human involvement | Yellow: Lawyer and AI draft together |
| How AI is used | List documents that bear on the questions the lawyer supplies, and flag a question with no document. Do not state whether a tax position is correct. |
| What the lawyer must review | You decide which points are issues and what to ask the seller. Formal Opinion 512: a generated issue is not an issue until you have checked it against the document. Office of Professional Responsibility Issue 2026-19: verify facts and citations. Model Rule 1.6: the data room does not go into a public tool. Privilege, including 26 U.S.C. § 7525 where it applies, is decided before a document is uploaded anywhere. |
| Written for | United States |
| Applies to | [Build a tax due-diligence issues list from the data room](https://ailawframework.com/practice/taxation/build-a-tax-due-diligence-issues-list-from-the-data-room.md) |

## Checking plan

- What the AI does: List documents that bear on the questions the lawyer supplies, and flag a question with no document. Do not state whether a tax position is correct.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- The list follows the lawyer's questions. It does not invent a tax theory.
- A missing document stays flagged. It is not treated as a clean answer.

## Sources

- [ABA Formal Opinion 512, Generative Artificial Intelligence Tools (29 July 2024)](https://www.americanbar.org/content/dam/aba/administrative/professional_responsibility/ethics-opinions/aba-formal-opinion-512.pdf) (checked 2026-10-22)
- [IRS Office of Professional Responsibility, Issue 2026-19, Introductory Guidelines for Responsible AI Use in Federal Tax Practice](https://www.irs.gov/pub/opr-taxpros/issue-number-2026-19-introductory-guidelines-for-responsible-ai-use-in-federal-tax-practice.pdf) (checked 2026-10-22)
- [ABA Model Rule 1.6, Confidentiality of Information](https://www.americanbar.org/groups/professional_responsibility/publications/model_rules_of_professional_conduct/rule_1_6_confidentiality_of_information/) (checked 2026-10-22)

## Forms and precedents for this task

| Form or precedent | Kind | AI level | Summary |
| --- | --- | --- | --- |
| [Tax due diligence request list and issues register (share or business acquisition of an Australian private company)](https://ailawframework.com/precedents/taxation/tax-due-diligence-request-list-and-issues-register.md) | Checklist | Yellow | Buy-side tax due diligence request list and issues register for an Australian private company: income tax, Division 7A, GST, PAYG and super (with incoming director penalty exposure), state taxes and… |

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.*