David D. Stewart: Welcome to the podcast. I'm David Stewart, editor in chief of Tax Notes Today International. This week: How do you spend $80 billion?

On April 6, the IRS released its long-awaited spending plan for the $80 billion allotted to it in the Inflation Reduction Act. The plan includes spending initiatives, as well as budget information for the next three fiscal years. What kind of response has the plan gotten in the tax community?

Well, joining me now to talk more about this is Tax Notes senior reporter Jonathan Curry.

Jonathan, welcome back to the podcast.

Jonathan Curry: It's good to be back, Dave. I've had a nice long paternity leave and I am ready to talk about the big strategic operational plan.

David D. Stewart: Well, we are glad to have you back. First of all, could you give us a quick rundown of what we saw in the plan?

Jonathan Curry: Yeah. As you mentioned, it came out last week. I'll note that that was about four days after I returned from paternity leave. And while the IRS didn't say it in their press release, I'm sure they were waiting for me to get back. Reading between the lines, we know. That was very, very respectful of them.

But this plan, it came out last Thursday. As you said, it's highly anticipated. There's been a lot of talk for the last seven-plus months about what's going to be in this plan, and now we have a pretty good idea of what the IRS is envisioning. A lot of it is fairly high level. It's not the most granular detailed document, but it's 150 pages. I mean, granted 10 or 15 of those pages are filler blank spaces or graphics and things like that, but it's a fair amount of detail. It's a pretty comprehensive thing.

Just to recap again, the Inflation Reduction Act provided about $80 billion. The IRS was essentially given kind of like a carte blanche to do with it whatever it sees fit with some oversight from Congress, but also within these four buckets of funding.

The $80 billion is divided into about a little over $45 billion for enforcement. If you're a math wizard, you'll realize that that is over half of the $80 billion going to enforcement. A little over $3 billion goes to taxpayer services and about $25 or so billion for operation support and just shy of $5 billion for IRS to modernize its IT and business systems. The plan itself fleshes out what it's going to do in a couple different areas.

Specifically, it has five key objectives. And then underneath that, it lays out different initiatives; underneath those are divided into projects. And then those projects, a lot of them have milestones. It's a good amount of interesting detail there.

Just to recap though, these objectives, the first one would be, the IRS wants to really expand its capabilities on the customer service side. There already are taxpayer accounts online you can access for some basic functionality, but they want to supercharge that to where you can do a whole lot more than before and a lot of other things along those lines. They want to make it easier to contact the IRS, not just on the phone, but just through online messaging as well.

The second objective is similar to the customer service side. It's a taxpayer service bucket of initiatives here. What this one is it's quickly resolving taxpayer issues when they arise. The taxpayer makes a mistake and then the IRS clobbers them six months later with an audit notice or something like that. They want to do things like automatically fixing a taxpayer's return that has a pretty clear math error. Rather than something that triggers it having to get extra scrutiny, it can just be fixed quickly and easily without causing a fuss.

They also want to make it easier for taxpayers to set up installment agreements to pay back taxes if they owe taxes. It's not this complicated procedure. They already have a lot of these things in place currently, but they just want expand it, make it more accessible, easier to understand.

The third objective is boosting enforcement. The Biden administration's been very clear that they want to stick by the "capital P" pledge. That's become a bit of a famous talked about thing here where Treasury Secretary Janet Yellen and President Biden have pledged not to raise the audit rate on those earning less than $400,000 relative to historic norms. They really emphasized that they're going to be using this enforcement money to go after high-net-worth taxpayers with complicated tax situations, and that's where they're going to try to close the tax gap between taxes that are owed and taxes that are actually paid.

They also want to modernize the IRS's technology. The IRS is infamous in the government world for its outdated systems. Yes, they have made a lot of updates along the years. There's a common talking point that its database is based off of 1960s technology. There's some truth there — it's also not entirely a fair picture necessarily — but they do want to fully modernize their systems where that talking point just disappears completely. They want to replace the master file database. They want to use data to target their audits more carefully so they're not targeting taxpayers who are compliant, but actually finding taxpayers who are noncompliant.

And then the last objective, No. 5, is they want to hire a more skilled and diversely skilled workforce as well.

Another interesting thing about the plan, too, it emphasizes taxpayer service. If you recall what I just talked about with the budget breakdown, taxpayer service was technically only given a little over $3 billion in this plan, but taxpayer service projects take up, I think, around 40 percent of the actual document itself. They are clearly emphasizing that this is going to be good for the average taxpayer, but they've also pointed out that all these plans on the taxpayer service side might start to run out of funding pretty quickly, even with the extra $80 billion because of the restrictions on how it can be spent in those buckets.

There's a lot to unpack there, but I had a good conversation today with someone who's going to do that for us.

David D. Stewart: Let's get to that. Tell us about your guest.

Jonathan Curry: I had the privilege of talking to the illustrious Fred Goldberg Jr. from Skadden. He's had a long and busy career in the tax world. Perhaps most relevant for our conversation today is that he is a former IRS commissioner himself. He was an IRS commissioner from 1989 to 1992, but he's also held roles like IRS chief council, Treasury assistant secretary for tax policy, and he's definitely a fixture in the tax world that has a lot of good insight, especially for this topic that we're talking about today.

David D. Stewart: Great. What sort of things did you get into?

Jonathan Curry: I don't want to spoil too much. You'll realize he's impressed with what he sees in the plan. He likes what the IRS — he thinks they have a cohesive vision, and he sees some notable shifts in how the IRS is approaching tax administration. And then also a lot of it is about the IRS doing more of what it's already doing now, but doing it so much better than what it's been doing. He thinks that's going to have a pretty big impact on both the average taxpayer and the wealthiest, the big IBMs and Boeing corporations of the world as well.

David D. Stewart: Well, all right. Let's go to that interview.

Jonathan Curry: All right. Well, Fred, thank you for being with us here today.

Fred T. Goldberg Jr.: Thanks, Jonathan. It's a treat to be here. I've been a Tax Notes fan from the very beginning, so it's a pleasure.

Jonathan Curry: Yeah, no, same here.

Fred T. Goldberg Jr.: And a great topic.

Jonathan Curry: Yeah, absolutely. Very relevant right now. Kind of a hot topic these days. Let's just dive right in. We have this new strategic operational plan. It came out Thursday, April 6. I would love to start with your high-level, 30,000-foot view on the plan. The IRS had about a little over six months — well, more like seven months — to game out their plan on this. Does it look like they're just kicking back with their heels on the table, or does it show signs of a lot of thought?

Fred T. Goldberg Jr.: It's an extraordinary document, truly extraordinary, and it's worth the hours that it takes to go through it carefully and think about what they're saying. They wisely waited until after the commissioner was confirmed because that's his job. They picked the right guy, but he has to have some input, and he did.

From a high level, it reflects what the career organization has known for years and years and years should be done, needs to be done. But for lots of reasons, it didn't. A lot of it didn't happen. It was funding issues, different technologies and all, but it captures a comprehensive view of how the IRS sees itself going forward. And that is terrific.

It's also aligned with the commissioner's great leadership skills, and he's the right guy for the job. The plan is aligned with broadly at a high level how he sees the system. It's terrific, but you need to read it. You can't skim it, you can't generalize, because there's so much going on there. It's terrific.

Jonathan Curry: I thought you made an interesting point that it's not like the IRS just sat down last August after the bill is enacted to just start from scratch essentially. A lot of these things have been on the table for a long time and now it's being mushed together into this one document. Is that about right?

Fred T. Goldberg Jr.: As Secretary Yellen likes to describe it, it's stable funding. Other folks refer to it as long-term funding. This is the chance. In a very real way, the IRS has never had this chance before. What differentiates Commissioner Werfel from all the rest of us, there's stable funding, and that's what makes this happen or can let this happen.

Jonathan Curry: If you look at this plan, there's a lot of good things. They have nice graphics showing the IRS of the future, people using their phones to access an online taxpayer account. They talk about all kinds of shifts on technology and modernization. That's a happy-sounding IRS, I have to say. It's a pretty optimistic vision, but a vision is still a vision. As a former IRS commissioner yourself, do you see this as a realistic and achievable plan?

Fred T. Goldberg Jr.: I think at least the way to think about it, as an abstract matter, most of what is here, "Oh, I get this, this makes sense." But that doesn't really answer the question.

The way I see it, there are two risks and three challenges. The two risks have to do with protecting taxpayer information and confidentiality and setting priorities. The three challenges are around services, enforcement, and HR protecting confidentiality in private.

Every month we're reading about private sector issues, government issues. If you actually look at the record, the IRS has done a very good job. It's been strangely silent about ProPublica, but they have to do the best they can because that's what taxpayers have a right to expect, and they have to improve as technology improves.

Jonathan Curry: Very little room for error it sounds like. Because when that ProPublica leak came out, hearings were called. One mistake starts sort of a snowball effect of attention.

Fred T. Goldberg Jr.: But it goes to candor and expressing anger and outrage and chasing the folks who are doing it. Ask all 300 million of us who's perfect. Nobody's going to raise their hand. But it's a very high priority and that's clear throughout the plan.

When you get to priorities, the plan has five objectives, it has 42 initiatives, and it has 192 key projects. Well, that tells you a lot. There is no way they can do all of them at once. Not a chance. If you decide, "I'll do a little bit of all 192," it's still not going to work. You need to set priorities.

Also, it's important for those outside the IRS to understand the profound difference between honest, candid oversight, support, and micromanaging. Micromanaging can be a big hindrance to this entire thing. When you get to priorities, Commissioner Werfel's history, the time some of us have been privileged to spend with him, he gets the need to set priorities. A number of his most senior staff and staff he's going to be bringing in understand you need to set priorities.

Jonathan Curry: And just to clarify, Commissioner Werfel was a former IRS acting commissioner, and he also spent a lot of time in management consulting as well.

Fred T. Goldberg Jr.: Yeah, and dealing with governments. But he's a smart guy and the priorities is a practical matter. I think the judgment of most of us who see this get the service portion right. They've already started doing it. It is transformational. They can get it up and running — several of them are already up and running — and they really have two years to show they know how to do what they're doing. And that's where at least most of us believe the focus should be.

Jonathan Curry: To your point, the filing season last year and even the year before as well, I mean, I don't know many people would say anything more kindly than it was a disaster. This year there hasn't been nearly as much.

Fred T. Goldberg Jr.: Jonathan, some of us would say the fact that they kept the filing season together at all was spectacular.

Jonathan Curry: Sure. Credit where credit's due.

Fred T. Goldberg Jr.: But for electronic filing, it would've failed. Completely failed. Yes, it was a disaster in terms of service, in terms of processing times, but the most likely alternative was complete collapse, and I think they deserve some credit for that.

Jonathan Curry: You also mentioned the threat of micromanagement. Would you say the threat is more from Congress or from the Biden administration, like say Treasury?

Fred T. Goldberg Jr.: It's all the stakeholders because there's a difference between hard oversight accompanied by complete candor, which Commissioner Werfel is committed to. Oversight is so important, and he said that from day 1. That matters. Support structures, whether it's funding or whether it's Treasury using its resource, they play a very important role on compliance through guidance, for example.

But micromanaging never works, and it's hard to resist the temptation. If you're on a board of a company, don't micromanage the CEO. Oversight, stewardship, support. It's human nature. "Well, I know all this stuff. I'm going to tell you everything you should do." But he needs the independence, whether it's personnel or whether it's specific priorities and how they're executed. That's his job and that's leadership's job. Let him do it, but pay attention and be honest about it.

Jonathan Curry: You also raised hiring challenges. One of the objectives is to hire a skilled, diverse workforce with a range of talents that the IRS hasn't really been using yet, but you seem to be suggesting that might not be as easy as it sounds on paper.

Fred T. Goldberg Jr.: The way I see it, there are two risks: massive leaks unattended to. That is a huge risk. Failure to set and execute priorities is a huge risk.

But then there are three operational issues. HR, a lot of the stuff they say is really good. It feels good, it makes sense, but it is really hard to do and a lot of it is hard to assess. There's a very interesting thing about moving to a culture of service and support. That's great. That's great. How do you measure it? How do you do it? That's kind of tricky. The hiring challenge is because of the bureaucratic rules, the external rules is hard. I just think that's one of the three biggest challenges.

On the service side, you can break the services into two buckets. One are things that are doable, are measurable, quantifiable in terms of impact and can therefore be improved over time. That's a meaningful number of the key projects. Some of the service projects are important, but hard. How do you measure whether communication is easier and more easily understood? That's been something all of us have talked about for 40 years. It's not that it shouldn't happen. It's harder to do and its impact is harder to measure.

Thinking about these key projects, you want to think about which ones you do, which ones you prioritize. Because if you can't measure it and assess its impact and treat that as the foundation for "How am I going to do better next year and then the next year?" Because the whole theory of transformation is you start. You never start with a perfect answer. You start with an answer, improve, improve, improve. Some of the service pieces are hard to measure, and therefore, figure out how you improve.

On the compliance side, the issue is the word enforcement. Folks equate "enforcement equals audits." Now, the background for that is how the CBO and OTA (Office of Tax Analysis) score. CBO is one of the most remarkable institutions we have in our government. OTA is terrific professionals. They don't score the impact of technology, they don't score the impact of service, and they don't score changing ways of doing business. Well, that's what this whole plan's about and it's a convention that in some ways is understandable.

But if this is all about revenue, which enforcement is a part of, well, enforcement is just audits. That is not compliance. Enforcement is never an end in itself. Enforcement is one way to improve compliance. You need it. Civil and criminal audits are important, but it's only one. And what's beautiful about the plan is you read the plan and the IRS is so clear-sighted about all the other strategies in a global world with what's going on in international taxes, the advanced pricing and mutual agreements to resolve issues is spectacular tool for compliance.

Global resolutions. If thousands of taxpayers have done something that was too hinky, you can really audit every one of them, litigate all those cases for the next 20 years, or you're going to come up with viable global resolutions. There are other tools. Guidance is so important. Again, would you rather find something that you don't think makes any sense, audit, go to Appeals, go to court and roll your dice for 10 years on a court decision, or would you rather have Treasury provide guidance? Folks don't do this anymore.

Form redesign is another tool. So that if you read the plan carefully, the IRS totally gets that. But when you say enforcement, which is what is relevant for scoring, which is historic audit results, it's understandable because that's the way the rules are crafted. I get worried about that word because, "Oh, you're just going to go audit everybody." No, that's not what the IRS is going to do. It's not part of their plan. It is an important part of their plan, but a subset of a much broader approach.

Jonathan Curry: Now, for example, Natasha Sarin, the former Treasury counsel and the counselor to Treasury Secretary Janet Yellen, she tweeted when the plan was — she had worked on the plan extensively and was part and parcel of putting the Inflation Reduction Act together. She described the shift in the IRS's approach or mindset towards compliance as a fundamental shift in how the IRS sees compliance. It's less about penalizing taxpayers when they get it wrong and more about helping taxpayers get it right upfront or shortly after they file to avoid these long, drawn-out fights. I mean, would you agree that that sounds like a fundamental shift for the agency?

Fred T. Goldberg Jr.: I wouldn't say it's a fundamental shift in the sense they're doing things they've never done before. I think the shift is in prioritizing their entire set of ways of improving compliance. I think a culture that says enforcement equals audit and audit is our preferred approach, that's always been true. But if you read the plan, they're doing them already. Treasury's doing guidance already.

They've done all of these things, but it's what you put priorities on. Natasha's terrific. I mean, she is amazing. One of the HR objectives is a culture of service and support. Is it different or is it making far better use and giving far greater priority to tools they've already used in some? I would put it the latter way, but it's a big change.

Jonathan Curry: Fred, Commissioner Werfel said the agency wants to leverage technology and automation. They want to bring in data scientists, and they really want to change how the IRS does things internally. One of the criticisms the plan got was, for example, that it only provides projections of staffing how many people it wants to hire for the next two years. Commissioner Werfel explained that as saying, "We want to see where we're at. And then based on where we're more efficient, that'll change what needs we need to fill on the staffing front."

Do you think it's doable for the IRS to be able to really make some big changes internally? Just simply using technology data to really change almost like the composition of the IRS's staff?

Fred T. Goldberg Jr.: Short answer, yes. I think that the criticisms about there are not enough details or not projections, criticisms the IRS doesn't know what it's doing and screws up, there are all these criticisms out there. They're completely unfounded in my view. Because the reality, the real world of transformational change in the private sector is you learn as you go. You're doing something different because you want to accomplish something. Well, once you're doing something different, it improves over time.

It goes back to the service stuff. Do stuff that you can measure and show it works and show how you can improve it. Some of the critics love the service, love the system, are very well-intended. But I think that understanding transitional change in a very large organization where technology is one of the most important drivers, and as you say, the workforce needs are going to change over time. It's hard.

The beauty of all this, if you read carefully, like for example, the key projects, if you read them fairly and carefully, there is both explicit and implicit acknowledgement. "This will take time and we need to improve." That gets you back to priorities. If they're trying to do every one of these right now or bits and pieces of every one, it's just not going to work. Commissioner Werfel understands it. Senior staff understands it. I just don't think those criticisms are grounded in reality. Commissioner Rossotti, Commissioner Koskinen, and myself published an article in the best publication of the country, Tax Notes, on March 13.

It lays out five initiatives that are already underway that objectively will transform how tens of millions of taxpayers will deal with the IRS. It's stunning. Are they perfect? No. Will they improve and improve and improve? They can, yes. Can you measure the impact by counting the taxpayers, getting feedback from taxpayers and practitioners? Absolutely. Well, if you really think you better put some points on the board over the next year or two, they're there for the taking.

I think the Service understands that. These are the ones that taxpayers and advisers care about most: electronic posting of data, converting paper to digital, self-help, get your collection, being able to do your offer and compromise to make payments, phone calls answered the first time. And you set the terms, being able to resolve office correspondence and desk audits with one person, where you can post the documents, where you can see your file. It's hard to capture how different that's going to be for folks. It's measurable and it's doable.

Jonathan Curry: Yeah, it's very interesting you point out a lot of these things like the electronically sharing documents, setting up these installment agreements over the phone. Those have been tools that the IRS has been working on. It sounds like a lot of what this plan is doing is taking what they've been doing and just supercharging it or making it more robust. They have online taxpayer accounts where you can check some basic functionality, but they want to make it more robust so that now you can actually interact or post documents or receive notices electronically and getting rid of the paper trail that oftentimes is where a lot of bottlenecks and things break down, where it's like, "Well, I didn't get that letter."

Fred T. Goldberg Jr.: Exactly, Jonathan. As Secretary Yellen puts it, stable funding. Others call it long. That's the only way this can really work, but they have to start showing results. One of my favorite little things in this is taxpayer and practitioner use of technology is optional. Folks don't like to be ordered to do things by their government. They like to have control. Electronic filing worked because it was never mandated, and over time folks got comfortable with it.

ID.me didn't work because everyone was told they had to use it. Folks don't do that. The new system they're going to, and if you read the plan time and again, it's optional. That works for us. That's our national character. Don't tread on me. I think that shows a really important understanding that has been expressly articulated.

Jonathan Curry: We touched on this a little bit earlier, but the criticisms of the plan, we'll go over a few of the criticisms that have been out there, whether it's, like you mentioned, some of it is politically charged, others are from people who are fairly trying to get the IRS where they want it to go.

One of the criticisms I've seen often is that the plan includes around 200 or so milestones. They have all these projects, then they have milestones, like we're going to finish. Success looks like rolling out a taxpayer account where they can send emails directly to an auditor by fiscal 2024. I'm making that up, but something like that where it's sort of a "Here's our benchmark that we're setting for ourselves." But some of the criticism was that a lot of these milestones are a bit vague. It's just "improve customer service by fiscal year 2023" or something like that. How would you respond to the criticism that the plan is a bit vague and a lot of these objectives are unquantifiable?

Fred T. Goldberg Jr.: This is why reading the plan, and it's ours, to try to get your head around what's really going on here. At least the way I read the milestones and the way I read the key projects, there is not a point in time on December 31, 2025, when we will have achieved perfection and we're done. It doesn't work that way. I think that the lack of specificity is both appropriate and realistic. Technology is changing at light speed. Nobody knows what technology's going to be like in two or three years and how it facilitates the kind of work the IRS is trying to do.

I think that's the answer to that question is "you would be foolhardy." It would be affirmatively misleading saying, "We will hire this number of people each year for 10 years. This is the technology we're going to use for the next 10 years. This is exactly the number of good things that are going to happen to this number." Nobody knows. Nobody in the private sector knows when they're trying to transform their business. I just don't think that criticism — it's well-intended sometimes.

It's publicly politics in our current environment, but treating taxpayers right and giving service, that is about as bipartisan an issue as you can have. Folks should do their job. Congress has to play a fundamental role in accountability and oversight. I don't know if I'm answering your question. I just don't buy that. The approach they are taking at this stage strikes me as practical and reasonable.

Jonathan Curry: Another criticism I've heard, this one's a little more from the stauncher critics of the IRS, is that the IRS has $80 billion to spend and it is just in over its head and there's no way it's not going to screw this up. Do you think that things are different this time around? The IRS has had some notable failures in the past when it comes to some things where it's gotten extra funding for modernizing things and it just hasn't really delivered the way Congress perhaps envisioned it would. What's different this time?

Fred T. Goldberg Jr.: What is profoundly different? Thank you, Secretary Yellen, for the way you clarified. She's absolutely right. It is stable funding. We all live in an annual accounting period for tax purposes. That's when we file our returns. But transformative change doesn't happen to the tax year. It happens over time. I think that what is fundamentally different is the stable funding coupled with a clear picture that includes things. It's optional, not mandatory. We listen to outsiders.

We're open to change. We're open to feedback. I think all of those things are true, and a fair reading of the plan tells you they're true. That's what's different this time. It makes it possible. Imagine running Tax Notes, imagine running IBM, imagine running Dunkin' Donuts. No idea what your budget's going to be next year. None. Zero. Could you run any of these organizations that way? Not a chance. And that's the big difference.

Jonathan Curry: Another key issue that's come up with surrounding this is where things stand with the pledge. If you've been following the developments around this, the Inflation Reduction Act, President Biden and Secretary Janet Yellen, they've pledged that audit rates on those earning less than $400,000 will not increase relative to historic norms.

They've certainly been a little bit cagey perhaps in the past about what historic norm they're really going by, but Commissioner Werfel has also emphasized that in audit rates, he said that all their attention's going to be focused on this high-net-worth segment of the population and big corporations when it comes to spending this new enforcement. Do you think that that should satisfy critics or satisfy concerns that the IRS is going to be going after Mom and Pop down the street?

Fred T. Goldberg Jr.: I don't know. There was a president at one point who said, "Trust, but verify." I think that Commissioner Werfel over the last couple of weeks has been absolutely clear, we're not going to be playing games. There is no way the audit coverage for those making less than $400,000 is going to anywhere near approach the historic audit coverage. This is not, "Well, I'm going to pick the highest audit coverage you've ever been and that's going to be my benchmark." That's a game. He's not playing those games, and he's been quite explicit about not playing those games. That's reassuring.

I think the high end, I think the biggest challenge there is they want to hire folks who can do this, but I think they have so much to learn about compliance issues at the high end. I would not go crazy with the hiring of agents. I would spend my time doing the research to understand what I don't know, but what I do need to know to be effective. And that is both identifying issues and finding the most effective way to deal with those issues. Sometimes it's an audit, sometimes it's penalties, sometimes it's criminal enforcement.
But I think an awful lot of the time it comes to things like guidance, innovative dispute resolutions. I would be paying a lot of attention first to figure out, "What am I looking at here? What are the issues and how do I deal with them?" Because I think they have a lot to learn.

Part of the reason they have a lot to learn is they just haven't been auditing these organizations, and they are not provided with the base data. Time and again, the agent comes out and they have not been told what they're looking at. They can do discovery and tell the big company or the partnership or whatever, "How are you structured and what's it all look like?" But the IRS can get or has most of that data. In a world where you can equip agents with that information and you can assess the information based on your understanding of compliance issues, you're going to dramatically reduce the no-change audits rate, and you're going to do a better job with the ones you do. But that's hard.

It's going to take time, and promising what it's going to look like and promising exactly when you're going to audit how many folks and how much you're going to collect is nonsense. The criticisms, they're understandable, but you wonder, those making those criticisms, how familiar are they with businesses that are pursuing transformational change with technology and a more robust workforce?

One of the beauties of this whole thing, Jonathan, is I've lived in the tax world for 50 years, but Commissioner Rossotti, Commissioner Koskinen, to some extent Commissioner Everson, have lived in world of business. They're not tax folks and their insights on how real business succeeds and works is invaluable.

Jonathan Curry: Just to wrap up our conversation here, one final question for you, Commissioner Werfel is the new commissioner. He'll be serving a five-year term or at most a five-year term as long as he wants the job, I suppose.

Fred T. Goldberg Jr.: Maybe two five-year terms.

Jonathan Curry: That's true.

Fred T. Goldberg Jr.: That's his 10-year funding.

Jonathan Curry: That's right. Maybe he'll do so well, they just want to keep him around. Now, you've sat in the commissioner's seat before as well in the early '90s. Looking at where he is now, do you envy the job that he has right now, that he has $80 billion to essentially play around with and create the agency he desires? Or is it more of a pity knowing that there might be a bit of a political target painted on his back for as long as he's sitting in that chair at 1111 Constitution Avenue?

Fred T. Goldberg Jr.: You get a lot of questions. Why would anybody in the right mind want to do this? The IRS is the only institution in this country where every one of us — rich, poor, any definition, business, small business, big business, international business, nonprofits, religious organizations, my executor when I die — has to deal with the IRS, and getting that right is so important to our country because it's the one shared experience.

The chance to finally be able to do that with stable or long-term funding and with technology where it has gone over the last 10 years and where it is likely to go for better as well as for worse over the next period, Jonathan, this can happen and it's so important, whether it's been your life for 50 years or whether it's been folks who understand and run extraordinarily successful businesses who've served.

Got to give me 30 years back, but I'd love to do the job. I think most of us feel that way. Is it going to be hard? Are we going to constantly have a target on our back, his back? For sure. But the good that could be done and a guy who I think understands how to do it, of course, he wants the job.

Jonathan Curry: Well, Fred, thank you so much for joining us today. It's been a pleasure talking with you.

Fred T. Goldberg Jr.: Jonathan, it's been such a treat being here. Tax Notes really does something important, and thanks for letting me do this.

David D. Stewart: And now, coming attractions. Each week we highlight new and interesting commentary in our magazines. Joining me now is Executive Editor for Commentary Jasper Smith. Jasper, what do you have for us?

Jasper B. Smith: Thanks, Dave. In Tax Notes Federal, Jason Chen explores the ways that ChatGPT could transform the tax profession. James Atkinson explores the tax planning significance of the tangible property regulations under sections 162 and 263(a).

In Tax Notes State, Karl Frieden and Douglas Lindholm critique the policy arguments made in favor of a permanent digital services tax at the state level in the United States. Open Weaver Banks provide some highlights of New Jersey's unitary business case law and discusses the state's new statutory and regulatory definitions of a unitary business.

In Tax Notes International, Robert Goulder comments on a new research paper addressing account-level FATCA data. Thomas Horst shares his method for estimating the unrecognized tax benefit clawback rate by evaluating generally accepted accounting principles financial statement data.

In Featured Analysis, Joseph Thorndike examines President Richard Nixon's "Shock" speech of 1971 that proposed tax cuts, wage freezes, price controls, and suspended the convertibility of the U.S. dollar to gold in an effort to fight inflation.

And finally, on the Opinions page, Marie Sapirie examines public comments on the Inflation Reduction Act's section 6417 direct pay provision. Robert Goulder and professor Mitchell Franklin discuss college sports programs not-for-profit status and light of compensation for name, image, and likeness rights.

David D. Stewart: That's it for this week. You can follow me online at @TaxStew, that's S-T-E-W, and be sure to follow @TaxNotes for all things tax. If you have any comments, questions, or suggestions for a future episode, you can email us at podcast@taxanalysts.org. And as always, if you like what we're doing here, please leave a rating or review wherever you download this podcast. We'll be back next week with another episode of Tax Notes Talk.

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