---
title: "Draft US tax advice so it can survive Circular 230 § 10.37"
url: "https://ailawframework.com/practice/taxation/draft-a-tax-advice-letter-from-the-facts-and-the-issues-list/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A26-T1-R2-US"
practice_area: "Taxation"
tier: "yellow"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-09-23"
---

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

> Produce a first-draft advice letter from the facts and issues the lawyer supplies, with every citation marked unverified.

Canonical page: https://ailawframework.com/practice/taxation/draft-a-tax-advice-letter-from-the-facts-and-the-issues-list/united-states  
Last reviewed: 2026-09-23

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 | 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 | United States |
| Applies to | [Draft a tax advice letter from the facts and the issues list](https://ailawframework.com/practice/taxation/draft-a-tax-advice-letter-from-the-facts-and-the-issues-list.md) |

## Checking plan

- What the AI does: Produce a first-draft advice letter from the facts and issues the lawyer supplies, with every citation marked unverified.
- Basis: Checked against the linked sources on 23 September 2026. Confirm the current instrument before reliance.

## 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 2026-09-23)
- [IRS Office of Professional Responsibility and Circular 230](https://www.irs.gov/tax-professionals/office-of-professional-responsibility-and-circular-230) (checked 2026-09-23)

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