Week One Internal Memorandum and Client Letter (Due in 24h)

   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.