U.S. Tax Court Chief Judge Patrick Urda discusses the effects of the IRS’s staff changes and generative AI on the court and its continued evaluation of online access to documents. 

Listen to our episode with Judge Kerrigan: Updates From the Tax Court: Post-COVID Plans and New Funding

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Credits
Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producer and Editor: Jordan Parrish

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This episode is sponsored by Portugal Pathways. For more information, visit portugalpathways.io.

This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Tax Notes chief correspondent Stephanie Soong discusses the OECD’s recent pillar 2 side-by-side package deal and how countries are adapting to the new landscape. 

For related tax news, read the following in Tax Notes:

• U.S. Focusing on OECD Guidance for Pillar 2 Side-by-Side Package
• Hungary Expands Global Minimum Tax Registration Form
• U.S. Treasury Officials Declare Death of OECD Pillar 1

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Credits
Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes

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This episode is sponsored by Portugal Pathways. For more information, visit portugalpathways.io.

This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Rozeta Atlas of HubSync discusses the IRS’s plan to overhaul its legacy IT systems and what a modernized agency may mean for practitioners.

For related tax news, read the following in Tax Notes:

• Palantir Contracts Under Scrutiny Amid IRS Tax Data Controversy
• IRS Adopts Generative Artificial Intelligence Policy
• IRS No-Paper Initiative Jammed by Staffing Issues, Watchdog Says

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Credits
Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes

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This episode is sponsored by Portugal Pathways. For more information, visit portugalpathways.io.

This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Professors Jeremy Bearer-Friend and Sarah Polcz discuss their recent paper, “Sharing the Algorithm: The Tax Solution to Generative AI,” which outlines their proposal for taxing generative AI companies.

For more, read Bearer-Friend and Polcz's article.

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Credits
Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes

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This episode is sponsored by Portugal Pathways. For more information, visit portugalpathways.io.

This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Professor Andrea Campbell, author of Taxation and Resentment: Race, Party, and Class in American Tax Attitudes, discusses why Americans' beliefs about taxes often don’t align with the specific tax policies they support.

For more on Taxation and Resentment, you can read Joseph Thorndike's book review here: "ANALYSIS: Why Do Americans Ignore Their Self-Interest When It Comes to Taxes?"

If you're interested in hearing more about Andrew Kahrl's research on the property tax, check out our episode, "Tax or Theft? Examining the History of the Property Tax." 

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Credits
Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes

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This episode is sponsored by Portugal Pathways. For more information, visit portugalpathways.io.

This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Damien Martin and Tony Nitti of EY discuss the second three of their top six tax cases of 2025, focusing on what qualifies as a deduction in Savage v. Commissioner, Kelly v. Commissioner, and Weston v. Commissioner.

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Credits
Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes

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This episode is sponsored by Portugal Pathways. For more information, visit portugalpathways.io.

This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Damien Martin and Tony Nitti of EY analyze the first three of their top six tax cases from 2025, focusing on what constitutes income in CF Headquarters Corp. v. Commissioner, Franklin v. Commissioner, and Feige v. Commissioner.

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Credits
Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes

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This episode is sponsored by Portugal Pathways. For more information, visit portugalpathways.io.

This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Philip Hwang, national chair of the Taxpayer Advocacy Panel, discusses the issues the IRS and return preparers could face this filing season following the passage of the One Big Beautiful Bill Act. 

For related tax news, read the following in Tax Notes:

• IRS Prepared to Meet Service, Collection Goals, Bisignano Says
• Proposed IRS Funding Cut Draws Concern From Tax Watchers
• IRS Sets Filing Season Start Date Amid Lofty Refund Expectations

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Credits
Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes

****
This episode is sponsored by Portugal Pathways. For more information, visit portugalpathways.io.

This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Jaye Calhoun of Kean Miller discusses key tax issues that states will likely address in 2026, including One Big Beautiful Bill Act provisions and the adoption of artificial intelligence tools. 

For related tax news, read the following in Tax Notes:

• Iowa DOR Issues Withholding Guidance on OBBBA Tax Deductions
• U.S. Chamber Backs Florida Bid to Challenge California Apportionment Rule
• States to Face Budget, Tax Policy Questions in 2026 Conformity Debate

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Credits
Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes

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This episode is sponsored by Portugal Pathways. For more information, visit portugalpathways.io.

This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Tax Analysts Chief Operating Officer Jeremy Scott reviews the 2025 developments in U.S. tax legislation and speculates what may lie ahead in 2026.

For related tax news, read the following in Tax Notes:

• These Expiring Tax Provisions Could Get Renewed in 2026
• New Deficit Projections to Hinge on Giant Tax Bill, Tariffs
• More Clean Energy Credits Are Set to Expire in 2026 Under OBBBA
• Tips and Overtime Reporting Expected to Test Employers in 2026

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Credits
Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes

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This episode is sponsored by Portugal Pathways. For more information, visit portugalpathways.io.

This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Tax Notes reporters recap some of the most memorable stories they encountered in 2025, from the establishment of a "crypto church" to how the "no tax on tips" provision may apply to certain professions. 

For related tax news, read the following in Tax Notes:

• Will IRS Know Pornography When It Sees It for Tips Deduction?
• Pass Go, Collect Millions: Hasbro to Get Tax Breaks for Boston HQ
• Marital Discord Is No Defense to FBAR Penalties, U.S. Says
• Crypto Evangelist’s Tax Evasion and Other Convictions Upheld

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Credits
Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes

****
This episode is sponsored by Portugal Pathways. For more information, visit portugalpathways.io.

This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.