---
title: "Draft a submission on a matter already before IRS Appeals"
url: "https://ailawframework.com/practice/taxation/draft-tax-appeal-or-review-submissions/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A26-T1-R4-US"
practice_area: "Taxation"
tier: "yellow"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# Draft a submission on a matter already before IRS Appeals

> Draft the submission from the points the lawyer has settled. Leave every date and the mailing address blank, to be taken from the letter.

Canonical page: https://ailawframework.com/practice/taxation/draft-tax-appeal-or-review-submissions/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 | Draft the submission from the points the lawyer has settled. Leave every date and the mailing address blank, to be taken from the letter. |
| What the lawyer must review | You check every sentence before it is sent. Take the address and every date from the letter in the file. Do not write a period the letter does not state. The IRS page on preparing a request for Appeals is the starting point for how a matter reaches Appeals. You read it against this letter. Office of Professional Responsibility Issue 2026-19: verify facts, citations and calculations before submission. Formal Opinion 512: you remain responsible for the submission. |
| Written for | United States |
| Applies to | [Draft tax appeal or review submissions](https://ailawframework.com/practice/taxation/draft-tax-appeal-or-review-submissions.md) |

## Checking plan

- What the AI does: Draft the submission from the points the lawyer has settled. Leave every date and the mailing address blank, to be taken from the letter.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- Dates and the address come from the letter. They are not assumed.
- This is a submission on a matter already with Appeals. It is not the paper that opens the protest.

## Sources

- [IRS: Preparing a request for Appeals](https://www.irs.gov/appeals/preparing-a-request-for-appeals) (checked 2026-10-22)
- [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.*