---
title: "Prepare questions for the client before a ruling request"
url: "https://ailawframework.com/practice/taxation/prepare-an-information-request-for-a-return-position-or-ruling/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A26-A20260923-4-US"
practice_area: "Taxation"
tier: "yellow"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# Prepare questions for the client before a ruling request

> Draft questions for the facts the lawyer marks as missing. Do not draft the ruling request and do not answer the questions.

Canonical page: https://ailawframework.com/practice/taxation/prepare-an-information-request-for-a-return-position-or-ruling/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 questions for the facts the lawyer marks as missing. Do not draft the ruling request and do not answer the questions. |
| What the lawyer must review | You decide which facts are missing and whether a ruling is worth asking for. The questions are checked before they go to the client. Office of Professional Responsibility Issue 2026-19: verify facts before anything is sent to the IRS. Formal Opinion 512: you remain responsible for the request that is eventually filed. A question that assumes a fact the file does not contain is rewritten. Model Rule 1.6 applies to the file. |
| Written for | United States |
| Applies to | [Prepare an information request for a return position or ruling](https://ailawframework.com/practice/taxation/prepare-an-information-request-for-a-return-position-or-ruling.md) |

## Checking plan

- What the AI does: Draft questions for the facts the lawyer marks as missing. Do not draft the ruling request and do not answer the questions.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- These are questions to the client. They are not the ruling request.
- Do not put a figure or a date into a question unless the lawyer has supplied it.

## 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 2026-10-22)
- [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)
- [ABA Model Rule 1.6, Confidentiality of Information](https://www.americanbar.org/groups/professional_responsibility/publications/model_rules_of_professional_conduct/rule_1_6_confidentiality_of_information/) (checked 2026-10-22)

## Forms and precedents for this task

| Form or precedent | Kind | AI level | Summary |
| --- | --- | --- | --- |
| [Client information request and facts declaration for a private ruling application or return position](https://ailawframework.com/precedents/taxation/client-information-request-and-facts-declaration-for-ruling.md) | Letter | Yellow | Letter asking a client for the facts and documents needed for a private ruling application (or a contentious return position), with a facts checklist, a supporting documents list, and the written… |

Signed-in accounts can read the full text of each one.

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