The IRS's First AI Rules: Circular 230 Exposure After OPR Alert 2026-19
On-Demand · 2 CLE credits · October 14, 2026, 2:30 PM ET
OPR Alert 2026-19 puts AI-assisted tax work under existing Circular 230 authority. Learn to map AI errors to specific provisions, evaluate OPR referral and sanction exposure, and build documentation, billing, and supervisory safeguards your firm can apply now.
Existing Circular 230 Rules Already Reach Your AI Work
OPR Alert 2026-19 is the IRS's first formal guidance on artificial intelligence in tax practice. It creates no new rules. Instead, it activates six Circular 230 obligations that already govern every practitioner. At the same time, the IRS has consolidated OPR and RPO into a new Tax Professional Management Office.
The stakes are immediate. Let AI generate facts or citations without verification, and § 10.22 due diligence is in play. Bill full manual rates for AI-assisted work, and § 10.27 unconscionable fee exposure follows. Feed client tax data into the wrong platform, and IRC §§ 6713 and 7216 apply. Leave a junior associate's AI use unsupervised, and § 10.36 liability can
Key topics
- OPR Alert 2026-19: How the IRS's first formal AI guidance activates six existing Circular 230 obligations.
- Due Diligence and Fees: How §§ 10.22, 10.35, and 10.27 reach AI-generated facts, competence, and billing.
- Advice and Confidentiality: What § 10.37 written advice and IRC §§ 6713 and 7216 data limits require.
- TPMO and Enforcement: What the OPR and RPO consolidation changes and how the referral-to-sanction pipeline runs.
- AI Sanctions Wave: How court sanctions for AI-fabricated citations become predicates for Circular 230 discipline.
- Firm-Level Safeguards: How to spot risk indicators and design § 10.36 supervision that prevents referrals.
Agenda
- The Six Circular 230 Obligations AI Use Now Puts in Play
- Tax Practitioner Enforcement: The New IRS Office and the AI Sanctions Wave
Faculty
- Sharyn M. Fisk, Cal Poly Pomona
- Josh Youngblood, The Youngblood Group LLC
State accreditation
- AK: Approved for CLE Credits, 2 General
- AL: Approved for Self-Study Credits, 2 General
- AR: Approved for CLE Credits, 2 General
- AZ: Approved for CLE Credits, 2 General
- CA: Approved for CLE Credits, 2 General
- CO: Pending CLE Approval, 2 General
- CT: Approved for CLE Credits, 2 General
- DC: No MCLE Required, 2 CLE Hour(s)
- DE: Pending CLE Approval, 2 General
- FL: Approved via Attorney Submission, 2 General Hours
- GA: Approved for CLE Credits, 2 General
- HI: Approved for CLE Credits, 2 General
- IA: Pending CLE Approval, 2 General
- ID: Pending CLE Approval, 2 General
- IL: Pending CLE Approval, 2 General
- IN: Pending CLE Approval, 2 General
- KS: Pending CLE Approval, 2 Substantive
- KY: Pending CLE Approval, 2 General
- LA: Pending CLE Approval, 2 General
- MA: No MCLE Required, 2 CLE Hour(s)
- MD: No MCLE Required, 2 CLE Hour(s)
- ME: Pending CLE Approval, 2 General
- MI: No MCLE Required, 2 CLE Hour(s)
- MN: Pending CLE Approval, 2 General
- MO: Approved for Self-Study Credits, 2.4 General
- MS: Pending CLE Approval, 2 General
- MT: Pending CLE Approval, 2 General
- NC: Pending CLE Approval, 2 General
- ND: Approved for CLE Credits, 2 General
- NE: Pending CLE Approval, 2 General
- NH: Approved for CLE Credits, 120 General minutes
- NJ: Approved for CLE Credits, 2 General
- NM: Approved for Self-Study Credits, 2 General
- NV: Pending CLE Approval, 2 General
- NY: Approved for CLE Credits, 2 General
- OH: Approved for Self-Study Credits, 2 General
- OK: Pending CLE Approval, 2.5 General
- OR: Pending CLE Approval, 2 General
- PA: Approved for Self-Study Credits, 2 General
- RI: Pending CLE Approval, 2.5 General
- SC: Pending CLE Approval, 2 General
- SD: No MCLE Required, 2 CLE Hour(s)
- TN: Approved for Self-Study Credits, 2 General
- TX: Approved for CLE Credits, 2 General
- UT: Pending CLE Approval, 2 General
- VA: Not Eligible, 2 General Hours
- VT: Approved for CLE Credits, 2 General
- WA: Approved via Attorney Submission, 2 Law & Legal Hours
- WI: Approved for Self-Study Credits, 2 General
- WV: Pending CLE Approval, 2.4 General
- WY: Pending CLE Approval, 2 General