Artificial Intelligence, Real Obligations: OPR's AI Guidance and Implications for Circular 230
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AI tools now draft memos, summarize authority, and answer client questions in tax practices of every size. Circular 230 has not changed to match. The practitioner who signs the work still carries the duties of due diligence, competence, confidentiality, written advice, and reasonable fees, whether a person or a tool produced the first draft.
In this one-hour ALFi webinar, Sharyn Fisk, former Director of the IRS Office of Professional Responsibility, and Frost Law partner Peter Haukebo, Esq., examine what those duties require when AI handles part of the work. Terry Lemons, longtime IRS communications chief, moderates.
The discussion covers three areas:
- How each existing Circular 230 obligation applies to AI-assisted research, drafting, client communication, and billing
- The direction of the proposed Circular 230 amendments and what they would change for practitioners who use AI
- The enforcement trends OPR and the courts are tracking, including fabricated citations in filings and client data entered into public AI tools
Attendees will leave with a practical framework for using AI in their practice while protecting their license, their clients, and their fees.

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