[Free Guide 2026] You will be required to use AI to  complete this assignment. The new world of the practitioner requires  that you understand and can use AI. In addition, we need to understand  its limitations through actual use. 

You will be required to use AI to  complete this assignment. The new world of the practitioner requires  that you understand and can use AI

You will be required to use AI to  complete this assignment. The new world of the practitioner requires  that you understand and can use AI. In addition, we need to understand  its limitations through actual use.

Deliverables:

• Using at least two different  AI sources, e.g. ChatGPT, Copilot, Grok, etc. Please place the following  fact pattern into the two different AI platforms to see the differences  in the outcomes.

Facts:  A long time client of the firm, Francesco  Petrarch, who is from Arezzo, Italy originally 5 years ago, but has  become an American citizen in the past year advises you that he has a  pension account in Switzerland and has for the last 15 years.  The funds  in the account according to Francesco are not reportable funds because  it is a pension account not a bank account. The funds are in Euros and  the amount is $500,000 Euros.

Create a prompt requesting a detailed analysis of the issues you believe may be present using only the Internal Revenue Code for guidance.   ( I need a copy of your prompt).   Name the AI sources you used and  provide copies of the two results as part of the deliverables.

• Using the results from the  prompt. Request that the two AI sources you have chosen create (I) an  internal memorandum (in IRAC format) explaining the facts, issues, law  and analysis and conclusions and (ii) a client letter explain the  results to the client (do not rewrite the memo or the client letter yet,  that comes later)
• Using at least two different  AI sources, e.g. ChatGPT, Copilot, Grok, etc. Please place the following  fact pattern into the two different AI platforms to see the differences  in the outcomes.

Facts:  A long time client of the firm, Francesco  Petrarch, who is from Arezzo, Italy originally 5 years ago, but has  become an American citizen in the past year advises you that he has a  pension account in Switzerland and has for the last 15 years.  The funds  in the account according to Francesco are not reportable funds because  it is a pension account not a bank account. The funds are in Euros and  the amount is $500,000 Euros.

Create a prompt requesting a detailed analysis of the issues you believe may be present using only the Internal Revenue Code and Treasury Regulations for guidance.   ( I need a copy of your prompt).   Name the AI sources you used and  provide copies of the two results as part of the deliverables.

• Using the results from the  prompt. Request that the two AI sources you have chosen create (I) an  internal memorandum (in IRAC format) explaining the facts, issues, law  and analysis and conclusions and (ii) a client letter explain the  results to the client (do not rewrite the memo or the client letter yet,  that comes later)
• Finally – Take the memorandum  and client letter you believe are most helpful and correct and rewrite  the Memo and client letter in a format you believe is complete and that  you would turn in to your boss as your work product.

Step-by-Step Guide to Answering the AI Comparison Assignment

1. Understand the Purpose of the Assignment

This assignment is designed to test your ability to:

• Use multiple AI tools as a professional practitioner

• Evaluate differences in AI outputs

• Understand limitations and risks of AI-generated legal analysis

• Apply tax law reasoning using:

  • Internal Revenue Code (IRC)

  • Treasury Regulations

• Produce professional legal work product (IRAC memo + client letter)

👉 You are being graded on process, judgment, comparison, and final synthesis, not just AI output.

2. Break the Assignment Into Clear Phases

The assignment has four major phases. Treat each as a separate section in your submission.

PHASE 1: Initial AI Analysis Using the Internal Revenue Code Only

Step 1: Select Two AI Platforms

Choose two different AI tools, such as:

• ChatGPT

• Microsoft Copilot

• Grok

Clearly name them in your paper.

Step 2: Create Your First Prompt (IRC Only)

You must design the prompt yourself. This is graded.

What the Prompt Must Include:

• The full fact pattern

• Instruction to use only the Internal Revenue Code

• Request for issue identification and analysis

• Instruction to ignore case law, treaties, or commentary

Example Structure (Do Not Copy Word-for-Word):

• Role assignment (e.g., “Act as a U.S. tax professional”)

• Facts

• Scope limitation (IRC only)

• Output request (issues, analysis, risks)

👉 You must include the exact prompt text in your submission.

Step 3: Run the Prompt in Both AI Platforms

• Paste the same prompt into both AI tools

• Save the full, unedited outputs

Step 4: Present the Results

In your submission:

• Label each AI output clearly

• Identify which platform produced which result

• Do not edit or correct them yet

PHASE 2: Memo and Client Letter Generation (IRC Only)

Step 5: Follow-Up Prompt to Each AI Tool

Using each platform’s own analysis, ask it to generate:

1. Internal Memorandum

   • Must be in IRAC format

   • Written for internal firm use

2. Client Letter

   • Plain-English explanation

   • No citations required

   • Client-facing tone

⚠️ Important:

• You are not rewriting or correcting anything yet

• You are observing how AI structures legal work

Step 6: Include Both AI Versions

Your deliverables must include:

• Memo from AI Tool #1

• Client letter from AI Tool #1

• Memo from AI Tool #2

• Client letter from AI Tool #2

Label everything clearly.

PHASE 3: Repeat the Exercise Using IRC + Treasury Regulations

This phase mirrors Phases 1 and 2, but with a broader legal authority scope.

Step 7: Create a Second Prompt (IRC + Treasury Regulations)

Your new prompt must:

• Include the same facts

• Explicitly allow:

  • Internal Revenue Code

  • Treasury Regulations

• Exclude:

  • Case law

  • IRS publications

  • Tax treaties

Again:
👉 Include the full prompt text in your submission.

Step 8: Run the Prompt on Both AI Platforms

• Use the same prompt for both tools

• Capture full outputs

Step 9: Generate Memo and Client Letter Again

Repeat:

• IRAC memo

• Client letter

• For each AI platform

PHASE 4: Critical Evaluation and Final Work Product

This is the most important part of the assignment.

Step 10: Evaluate All AI Outputs

You should compare:

• Issue spotting accuracy

• Treatment of foreign pensions

• Reporting assumptions

• Use of authority

• Clarity and organization

• Errors, omissions, or hallucinations

You are not required to be perfect, but you must show professional judgment.

Step 11: Select the Best Memo and Client Letter

Choose:

• One memo (from either AI)

• One client letter (from either AI)

Explain briefly (1–2 paragraphs):

• Why these were the most accurate and useful

• What the other versions lacked or misstated

Step 12: Rewrite the Final Memo and Client Letter

Now you become the practitioner.

Your rewritten documents should:

• Correct AI errors

• Improve clarity and structure

• Maintain IRAC format (memo)

• Be client-appropriate (letter)

• Reflect something you would submit to your boss

This is your original work, informed by AI.

3. Recommended Final Paper Structure

Section I – Introduction

• Purpose of assignment

• Importance of AI in legal practice

Section II – AI Tools Used

• Identify the two platforms

• Brief description of each

Section III – IRC-Only Analysis

• Prompt

• AI outputs

• Memo and client letters

Section IV – IRC + Treasury Regulations Analysis

• Prompt

• AI outputs

• Memo and client letters

Section V – Comparison and Evaluation

• Strengths and weaknesses

• Limitations of AI

Section VI – Final Revised Work Product

• Final memo

• Final client letter

4. Common Mistakes to Avoid 🚫

• Changing prompts between AI tools

• Editing AI output before comparison

• Forgetting to include prompt text

• Treating AI output as “correct law”

• Failing to rewrite the final documents

• Not clearly labeling deliverables

5. What Your Professor Is Really Looking For

✔ Ability to design effective prompts
✔ Understanding AI limitations
✔ Professional skepticism
✔ Legal reasoning judgment
✔ High-quality final written work

6. Final Checklist Before Submission ✅

✔ Two AI platforms named
✔ Two prompts included (IRC-only, IRC + Regs)
✔ All AI outputs attached
✔ IRAC memos and client letters generated
✔ One memo and letter rewritten as final work product
✔ Clear organization and labels

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