Draft US tax advice so it can survive Circular 230 § 10.37

Key facts

Human involvement
YellowClose supervision
How AI is used
Produce a first-draft advice letter from the facts and issues the lawyer supplies, with every citation marked unverified.
What the lawyer must review
  • Check the advice rests on reasonable assumptions (IRS OPR 2026-19)
  • Authenticate citations, calculations and forecasts
  • Keep return information out of public tools (IRC §§ 6713, 7216)
Written for / version
United States versionUS

Rules that apply

The document starts from the task name. Change it if this piece of work is different.

Who does what

Who does what
RoleWhat they do
AssistancePotential support includes preparing preliminary structure or wording. Confirm the tool’s capability and permitted scope.
LawyerSet the scope, supervise the work closely, verify every part relied on, resolve omissions and exceptions, and approve the exact output.

Checklist

  1. Open each relied-on authority independently. Confirm its existence, current status, proposition and any quotation or pinpoint reference.
  2. Trace every relied-on figure to its source, confirm dates and assumptions, and independently recalculate totals or derived amounts.
  3. Preserve original files and relevant metadata. Document provenance and handling, and seek forensic review where authenticity needs to be resolved.
  4. Confirm the output against the client’s instructions and the complete relevant source material, including omissions or contradictions.
  5. Resolve exceptions and record the responsible lawyer’s approval of the exact output and intended use.

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