The IRS Office of Professional Responsibility’s bulletin on responsible AI use explains that existing Circular 230 duties fully apply when tax professionals use AI tools, especially generative AI. AI can improve efficiency in document review, research, and risk assessment, but its tendency to fabricate content, embed bias, and mishandle confidential data creates heightened professional‑responsibility risks.
Under §10.22 (due diligence), practitioners must independently verify AI‑generated facts, citations, and calculations before relying on them in advice, returns, or submissions. Section 10.35 (competence) now implicitly includes technological competence: understanding AI’s capabilities, limits, and error patterns. Section 10.36 requires firm leaders to adopt and enforce written procedures for AI use—training, secure data handling, tool selection, and quality control. Section 10.37 (written advice) warns against unreasonable reliance on opaque AI logic or projections without appropriate scrutiny. Finally, confidentiality provisions in IRC §§6713 and 7216 and Circular 230 §10.51(a)(15) underscore civil and criminal exposure when taxpayer information is fed into public or insecure AI systems.
For appraisers, the bulletin is a useful analog to USPAP and IVS obligations. USPAP’s Ethics, Competency, and Scope of Work Rules already require independent verification of data, credible analysis, and protection of confidential client information; using AI to draft narratives, suggest comparables, or summarize market data does not lessen these duties. Appraisers should treat AI outputs as preliminary drafts, verify them against market evidence and accepted valuation theory, implement written policies governing AI use, and avoid uploading sensitive client financials to consumer‑grade AI tools.




