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
| Role | What they do |
|---|---|
| Assistance | Potential support includes preparing preliminary structure or wording. Confirm the tool’s capability and permitted scope. |
| Lawyer | Set the scope, supervise the work closely, verify every part relied on, resolve omissions and exceptions, and approve the exact output. |
Checklist
- Open each relied-on authority independently. Confirm its existence, current status, proposition and any quotation or pinpoint reference.
- Trace every relied-on figure to its source, confirm dates and assumptions, and independently recalculate totals or derived amounts.
- Preserve original files and relevant metadata. Document provenance and handling, and seek forensic review where authenticity needs to be resolved.
- Confirm the output against the client’s instructions and the complete relevant source material, including omissions or contradictions.
- Resolve exceptions and record the responsible lawyer’s approval of the exact output and intended use.