Draft a written protest of proposed federal tax changes
Key facts
- Human involvement
- YellowClose supervision
- How AI is used
- Draft the protest from the examination letter and the file, listing each disagreed item and the reason, and leave the mailing address and the deadline as blanks taken from the letter.
- What the lawyer must review
- The IRS says a formal written protest is mailed to the address on the letter that offers the appeal, not directly to the Independent Office of Appeals. The office that proposed the change considers the protest first. The protest must be sent within the time the letter states. The IRS says that time is generally 30 days from the date of the letter. A small-case request is available only if the taxpayer qualifies; the IRS points to Publication 5 for how to prepare the protest. You check every figure and every citation against the letter and the statute before the protest is sent. Circular 230 § 10.22, as explained in OPR Issue 2026-19, requires that review.
- Written for / version
- United States versionUSCth
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.
- Verify the applicable jurisdiction and the version of each relevant law, rule or instrument in force at the material time.
- 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.