The IRS’s First AI Rules: Circular 230 Exposure After OPR Alert 2026-19

Sharyn Fisk, Former Director, IRS Office of Professional Responsibility and Professor of Taxation | Cal Poly Pomona

Sharyn Fisk served as Director of the IRS Office of Professional Responsibility from 2020 to 2025, where she was responsible for the agency’s oversight of the tax professionals who practice before the IRS under Treasury Circular 230, setting and maintaining professional standards for more than 400,000 practitioners nationwide. During her tenure she oversaw notable revisions to Circular 230, and she also led the Tax Provision Implementation Office, directing implementation of 34 tax provisions of the Inflation Reduction Act and the CHIPS Act. She brings more than 20 years of experience in tax law and currently serves as Professor of Taxation at the College of Business Administration at Cal Poly Pomona.

• Education & Credentials

Ms. Fisk earned a B.A. in Journalism from San Diego State University, a J.D. from Rutgers University, and an LL.M. in Taxation from the New York University School of Law. She is a certified tax law specialist with the California State Bar.

• Recognition & Leadership

Ms. Fisk is a Fellow of the American College of Tax Counsel. She served as Chair of the Tax Policy, Practice and Legislation Committee of the American Bar Association, as Chair of the Taxation Section of the Los Angeles County Bar Association, and as Chair of the Taxation Section of the Beverly Hills Bar Association. She completed a three-year term as a member of the IRS Advisory Council and chaired a task force on unenrolled return preparers for the Standards of Tax Practice Committee of the ABA Taxation Section.

• Professional Involvement

Ms. Fisk has written and spoken extensively before national, state, and local tax professional organizations on all aspects of civil and criminal tax controversy issues and on ethics in tax practice. Before joining the IRS, she was Professor of Tax at Cal Poly Pomona and Director of the university’s VITA program, and she has taught graduate and undergraduate tax courses at several colleges and universities, including Chapman Law School’s LL.M. in Taxation program. She has volunteered to assist unrepresented taxpayers on the pro se Tax Court calendar, served as an attorney-advisor for a low-income tax clinic, and supported the ABA Taxation Section’s Operation Stand-By and Adopt-A-Base programs, providing training to military VITA volunteers in San Diego.

• Experience

At the Office of Professional Responsibility, Ms. Fisk led the IRS office responsible for practitioner oversight, discipline, and professional standards under Treasury Circular 230. In private practice, she was a partner at Hochman, Salkin, Rettig, Toscher & Perez in Beverly Hills, where she represented hundreds of individuals, businesses, and corporate taxpayers before the IRS, the Department of Justice Tax Division, federal and state courts, and state taxing authorities. Those matters involved civil examinations and appeals, criminal investigations, and tax collection issues. Earlier in her career, she served as an attorney-advisor to the Honorable Maurice Foley of the United States Tax Court in Washington, D.C.

Josh Youngblood, EA | The Youngblood Group LLC

Josh Youngblood is an Enrolled Agent who runs The Youngblood Group LLC, a tax practice in Dallas, Texas, specializing in IRS representation for individuals and small businesses. He also runs Title 26 Labs, which examines how artificial intelligence and automation can be used responsibly inside a tax practice. He came to tax work after roughly thirty years in information technology, holds a cybersecurity certification from ISC2, and treats data security as part of competent tax practice rather than an afterthought.

• Education & Credentials

Mr. Youngblood is an Enrolled Agent, a Certified Tax Resolution Specialist, and a Certified Real Estate Tax Strategist, and he holds a cybersecurity certification from ISC2. He passed the 2025 nonattorney examination for admission to the United States Tax Court and is awaiting admission.

• Recognition & Leadership

Mr. Youngblood is a Fellow of the National Tax Practice Institute. He is the author of Josh & Taxes, a newsletter for tax professionals covering IRS representation, practice management, professional responsibility, and the technology and security questions that practitioners tend to ignore until something breaks.

• Professional Involvement

Through Title 26 Labs, Mr. Youngblood examines the responsible use of artificial intelligence and automation inside a tax practice. His writing combines representation experience with technical depth across taxes, technology, and the real work of running a modern practice.

• Experience

Mr. Youngblood’s practice at The Youngblood Group LLC concentrates on IRS representation for individuals and small businesses. His roughly thirty years in information technology preceded his tax career, and he applies that background to the data security and technology dimensions of modern tax work.

SESSION 1 – The Six Circular 230 Obligations AI Use Now Puts in Play | 2:30pm – 3:30pm

This session maps OPR Alert 2026-19 — the IRS’s first formal AI guidance — onto six existing Circular 230 provisions: due diligence (§ 10.22), competence (§ 10.35), fees (§ 10.27), written advice (§ 10.37), client confidentiality (IRC §§ 6713/7216), and firm supervisory procedures (§ 10.36). Attorneys will learn precisely how each obligation applies to AI-generated tax work and what documentation, billing, and governance changes the OPR now expects. Attendees leave with a concrete compliance framework they can apply immediately under existing enforcement authority — before any new rulemaking is finalized.

BREAK | 3:30pm – 3:40pm

SESSION 2 – Tax Practitioner Enforcement: The New IRS Office and the AI Sanctions Wave | 3:40pm – 4:40pm

This session examines the IRS’s newly consolidated Tax Professional Management Office (TPMO), how OPR enforcement actually works from referral through sanction, and the emerging sanctions landscape for AI-related tax practice violations under Circular 230. Attorneys will leave understanding which Circular 230 provisions map directly to AI misconduct, what triggers an OPR referral in the AI context, and how court-based AI sanctions precedent is being imported into tax practitioner discipline. Competencies gained include analyzing firm-level supervisory liability, evaluating dual-track federal and state enforcement exposure, and designing practical safeguards against AI-related Circular 230 violations.