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Artificial Intelligence, Real Obligations: OPR's AI Guidance and Implications for Circular 230

Tuesday, November 3, 2026 · 2:00 p.m.  |  Eastern Time (US & Canada) (GMT -5:00)

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Presenter
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Peter Haukebo
Partner
Peter Haukebo is a tax controversy attorney and Partner at Frost Law, where he represents clients in complex federal and state tax disputes. His practice includes handling IRS audits, appeals, and litigation with a particular focus on employment tax controversies and the Employee Retention Credit. Peter frequently presents to national audiences on tax procedure and controversy topics, blending technical insights with practical strategies. He is admitted to practice in Arizona and Maryland and before the United States Tax Court, Court of Federal Claims, Court of International Trade, and several District Courts. Peter previously taught in the Low Income Taxpayer Clinic at the University of Maryland School of Law and chaired the Taxation Section of the Maryland State Bar Association.
About
Program Field of Study: Taxes | Federal Tax Related Matters | Ethics
Program Level: Basic
Who Should Attend: CPAs, Enrolled Agents, Attorneys
Credits: 1 CPE, 1 CE, 1 CLE
Advanced Preparation: None
Prerequisite: None
IRS Program Number: JWRXB-T-00028-26-O
State Bar of Texas Program Number: 174338220

Join Sharyn Fisk, former Director of the IRS Office of Professional Responsibility, and Frost Law partner Peter Haukebo, in a discussion moderated by Terry Lemons, the IRS's longtime communications chief. The session covers how existing Circular 230 duties--due diligence, competence, confidentiality, written advice, and fees--apply when AI does part of the work, where the proposed amendments are headed, and the trends OPR and the courts are watching, from fabricated citations to client data in public AI tools. Attendees will leave knowing how to use AI effectively without risking their license, their clients, or their fees.
Agenda
  • Explain OPR Alert 2026-19 and how its guidelines for responsible AI use map onto existing Circular 230 duties.
  • Apply Circular 230's due diligence, competence, written advice, and fee standards to AI-assisted work, including the verification required before AI output reaches a client or the IRS.
  • Compare current Circular 230 with the proposed amendments most relevant to AI, including the express technological-competence requirement.
  • Identify current enforcement trends--fabricated citations, confidentiality breaches, AI billing issues--and best practices for firm AI policies.
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