---
title: "Check each provision cited in a draft ruling request against the statute"
url: "https://ailawframework.com/practice/taxation/draft-a-private-ruling-request-and-check-each-cited-provision-against-th/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A26-B15-1-US"
practice_area: "Taxation"
tier: "yellow"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# Check each provision cited in a draft ruling request against the statute

> Set out each provision the draft cites and the draft's paraphrase of it, with a blank beside the paraphrase for the lawyer's reading. Do not confirm the paraphrase.

Canonical page: https://ailawframework.com/practice/taxation/draft-a-private-ruling-request-and-check-each-cited-provision-against-th/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 | Set out each provision the draft cites and the draft's paraphrase of it, with a blank beside the paraphrase for the lawyer's reading. Do not confirm the paraphrase. |
| What the lawyer must review | You open the statute or regulation named and you correct the paraphrase before the request is filed. Office of Professional Responsibility Issue 2026-19: verify citations before submission to the IRS. Formal Opinion 512: a generated paraphrase is not the statute. The procedures and user fees for a letter ruling are in the current revenue procedure, which you open. Do not treat this check as that procedure. |
| Written for | United States |
| Applies to | [Draft a private ruling request and check each cited provision against the legislation it names](https://ailawframework.com/practice/taxation/draft-a-private-ruling-request-and-check-each-cited-provision-against-th.md) |

## Checking plan

- What the AI does: Set out each provision the draft cites and the draft's paraphrase of it, with a blank beside the paraphrase for the lawyer's reading. Do not confirm the paraphrase.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- The blank is for the lawyer's reading of the instrument. The tool does not fill it.
- Open the current revenue procedure for how a ruling request is filed. This task does not restate it.

## Sources

- [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 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)

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