This transcript has been edited for clarity.

David D. Stewart: Welcome to the podcast. I'm David Stewart, editor in chief of Tax Notes Today International. This week: May it please the pod.

Patrick Urda began his term as chief judge of the U.S. Tax Court in June of 2025. He's settling in to leading a court that has had to consider the impacts of several notable tax and tax-adjacent Supreme Court cases as well as the changes at the IRS.

Now, if you're interested in hearing a bit from Chief Judge Urda's predecessor, Kathleen Kerrigan, you can find a link to that interview in the show notes.

But here to talk more about his interview with Chief Judge Urda is Tax Notes senior legal reporter Nathan Richman. Nate, welcome back to the podcast.

Nathan Richman: Always a pleasure.

David D. Stewart: So could you give us a bit of background on Chief Judge Urda?

Nathan Richman: He was appointed to the Tax Court in 2018 by President Trump. Before that, he worked at the Justice Department Tax Division on appeals.

David D. Stewart: And what sort of issues did he talk about?

Nathan Richman: We discussed his background, litigation trends in the court, and other court updates.

David D. Stewart: All right, let's go to that interview.

Nathan Richman: Well, welcome to the podcast. Thanks for joining us.

Patrick Urda: Thanks so much for having me. I'm excited to be here.

Nathan Richman: We're excited to have you. Let's start out with how you came to the Tax Court and what got you started in tax in the first place.

Patrick Urda: Sure. I had an unconventional path to tax more broadly. So when I came out of law school, I was more in the general commercial litigation mode, and that wasn't for any particular reason. My dad was a solo practitioner back in South Bend, Indiana, and he did lots of ERISA work, and then that also bleeds into trust and estate, so a lot of tax components, but more on the planning side.

When I was coming out of law school, even though I enjoyed my tax classes, I never really thought that was a path for me because the professors of tax were just so outstandingly brilliant. I've got a classmate now who's a professor up at Harvard, Tom Brennan. Now, that is a guy who you feel like, "That is a tax professor, that is a tax practitioner. He can do this." But Pat Urda, general commercial litigation, feels about right. And I wasn't coming off of a background of accountancy or anything more traditional. I was a classics major.

So when I got out of law school, I started at a private firm and just did commercial litigation, and that didn't quite click in the way that I was hoping. It didn't get me out of bed in the morning. But there were some experiences that really did resonate with me, and those experiences had to do with appellate arguments. And I had the opportunity to go back to South Bend where I'm from and clerk for a Seventh Circuit judge, and that deepened the connection with the appellate world. It just so happened that when I was looking for a job after the clerkship, there was a place at DOJ tax in the appellate section that was open.

So I threw my hat in the ring for that. And Gil Rothenberg, and Dave Pinkus, and Tom Clark, who were the leadership of the section, brought me on, and it was just the most revelatory and most wonderful time for a young lawyer. Both because they were exceptional advocates. Everyone there from the reviewers — Basically, the section was structured so you'd have the line attorneys, then you'd have reviewers who were basically the editors of the briefs, but they were also subject matter experts. So you'd really get to know this by working with Bruce, or Richard, or Terry, or John, you'd get to know particular subjects very well. But more than anything else, you have amazing people like Francesca Ugolini, and Judith Hagley, and Nate Pollock, and Andy Weiner, and Melissa Briggs, all these great folks. You spend enough time, you're just inundated with people who have a true passion for tax, and it's contagious. You can't not feel that.

And looking back, whether it's by osmosis with Dad in his own practice, which was more on the planning side, perhaps my mom who was a stats professor, so maybe some math did sink in there somewhere, I just don't know where. But then, working with such amazing colleagues and just seeing — I'd be remiss if I didn't also mention Diana Erbsen and Caroline Ciraolo. Those are the two most passionate tax lawyers you'll ever met. They just — they love it. Like so much in life, I think when you're around people who love a subject and you spend enough time with it, that deepens your appreciation and eventually you catch it, too. So that's what really brought me to tax law more broadly.

Nathan Richman: So what has been your favorite part of being a Tax Court judge, and is it something you had to give up when being elected to be chief judge?

Patrick Urda: Well, I think for me, the absolute favorite part is the people — are the people — and I have, and I haven't. And I'm going to break that down a little bit because I fundamentally believe that the job of a public servant is to serve the public. We're in the customer service business as judges, and we are there to try to give people answers so they can go about their lives. That has to do with the lawyers, but it also has to do with the people who have tax disputes with the government.

So our focus should be on them, and that's what I really loved — going out to a regular trial session, giving people their day in court, letting them have their opportunity to explain to me. Sometimes they'd do a good job, sometimes they would do a less good job. Sometimes they would need a lawyer to help, either represented or a pro bono person. Obviously, low-income taxpayer clinics pay a huge role in our work. But really, give me what the problem is from their perspective, and then allow the government to introduce their evidence, and let me see what Congress says about this situation.

So that's the special thrill about being a judge — being able to be there to help in that process. To listen to people and then try to decide, "OK, I've tried to understand what was going on as much as possible. Now, let's see what the law dictates here."

But another part of that are just the people that I see on a day-to-day basis. And those are just like any workplace, where all chambers are a small family. So we have Janet Mai. Right now we have my clerk Corey Kysor, and my former clerk Matt Marcelino unfortunately had to leave us. But those are the people that you see most proximately, and that's really your work family. And then you broaden out, and then you see all sorts of people just in the court who do so much important work to make sure that tax resolutions are possible and that we're able to complete the mission of the court just as well as possible. So obviously, Charles Jeane, our clerk of court, he has an amazing team top to bottom that really does the business of the court.

So when you ask, "Did you have to give up something you truly loved to be chief judge," as chief judge, you step away from —

Nathan Richman: New sessions.

Patrick Urda: — as many trial sessions — Exactly, exactly. So I have stepped away or stepped back. Not totally away — I still like to do at least one trial session of the regular sort per term. And then there are special sessions, I had one last week in Miami. It was a real labor of love to be out of beautiful D.C. weather to go down to Miami for a couple days, but that I've done the work for so can't really pawn off on somebody else. So I'm missing those people interactions, but on the other hand they've been replaced with stronger interactions on the administrative side, of just knowing the people who really, day in, day out, keep the court in business.

And I think that as judges, we appreciate that on a certain intellectual level. But as a chief judge, whether it would be Marvel, or Foley, or Kerrigan or myself, or Judge Cohen, of course, I think that that really comes home when you see these people and see how hard they work and how dedicated they are to the Tax Court mission.

Nathan Richman: So less interactions with taxpayers, more interactions with the court staff.

Patrick Urda: You said it so quickly and so well, and it took me a million minutes to get there.

Nathan Richman: Sorry.

Patrick Urda: No, you're the best. This is why you're doing what you're doing.

Nathan Richman: So Tax Court judges, they see some of these great, big billion-dollar tax disputes, but they also see everything else. What is the most entertaining or weirdest case that you've tried or decided?

Patrick Urda: Oh, I would have to go with a case involving mini-donkeys, but I think that this is a beautiful microcosm. So it was a case a few years ago in New York right before the pandemic, and it was really about a father and a daughter. So the father was a very wealthy guy, and he had a farm in New Jersey and bought some mini-donkeys for the farm. And I think that anyone who's been in the tax world long enough probably would have a gut reaction, "What's going on there?" — and whether it was a business or whether it was personal pleasure.

Well, we get up to trial, and he takes the stand. And he takes the stand for the better part of two days to talk about what he did and why he did it. And a lot of it really, he had tons of documentation of the work that he did. And because he was particularly blessed in terms of finances, he was able to get some excellent experts to help him set up this mini-donkey operation that had not done well, but he went through all of the things that one would do if they were trying to turn a buck. And I remember him just looking at me, and that's the nice thing about Tax Court, it's just you as the finder of fact evaluating the witness.

And he turned to me at one point in time and said, "Listen, you know how much I make. I'm fighting for $10,000, $15,000," whatever it was, "and the reason is because of my daughter. My daughter does not accept charity from me. She likes to live a very close to the earth lifestyle. She and her kids, she has a dog grooming business. And one of my friends said, 'Given your daughter's interests, this would be a beautiful business if you can get the genetics right and this would be something that could supplement her income in a way that she would enjoy it and you could know that you set up your daughter.'"

When I heard him explain and walk through everything that he did, it was pretty convincing in terms of his testimony that this was something even though on its face it looked pretty weird. Here's a millionaire, billionaire who's playing around with mini-donkeys. But then you understand what he did, why he did it, and then you go to the law, of course, and go to his documentation and say, "Yeah, he didn't turn a profit, but based on what he had done up to that point in time, that passes the test." It was such a bizarre case, especially because he capped off by saying, "The thing is, I hate these mini-donkeys. I absolutely detest them. They're ugly, they're smelly, they're all over the farm. And if it doesn't work in the next couple years, we're out of this business, but I had to give this a shot because I think it would help my daughter and that's what I care about."

I remember him saying, "I care about two things, my family and money." And in that moment all I could think was, "Yes. Yes, you do, sir. You have convinced me of those two things." I have to give credit to the government as well because it was an interesting case, and the government did a very able job. The true button on the case was in closing arguments. The government attorney went through the factors of hobby loss and then ended with, "And Judge, I don't think that Mr. Petitioner was credible." You see this petitioner, master of the universe type, getting red in the face and starting to stand up to talk to his lawyer. And he said, "Because how could someone not love this mini- donkey?" And he held up a picture of the mini-donkey, and everyone just burst into laughter.

It was a very well litigated case by the lawyers, and it was also a funny case. But it was a funny case that gave insights into sometimes people do things that we don't understand at first blush, and what we really need to do is get the information as much as possible to decide whether it's appropriate or not under the laws that Congress has passed.

Nathan Richman: You got to love when good craftsmanship meets good facts.

Patrick Urda: Oh, yeah, no. That's what you're waiting for, and it can come in unusual places, and it can come with unusual litigants.

I remember one of the best pro se people was a steamfitter out in Spokane, Washington. He was a foreman, so he had some supervisory skills. He had some background in leading a team, but man, oh, man, was he just a natural-born organized guy and very logical in the way that he presented everything. He was a very, very impressive litigant. You just never know who you're going to get when you step on the bench.

Nathan Richman: Speaking of interesting litigation, there have been a few notable cases coming out of the Supreme Court on tax and tax-adjacent issues in the last couple of years, some of which have addressed issues that many in the tax community had thought well-settled. Among Boechler, Zuch, Moore, Loper Bright and Jarkesy, which has had the biggest impact on the cases currently before the Tax Court?

Patrick Urda: Well, I would say that each of them have had significant impacts in their own way, and that's the job of the Tax Court. Our job is to look at what the Supreme Court has given us in instructions and always be responsive to what we see — try to apply it just as well as we can. Whether it's Loper Bright, obviously we've had a number of decisions over the last couple of years where we've started to integrate that framework. But being a trial court, we're always in the position of keeping one eye on the principles articulated by the Supreme Court and also looking at developments in the circuit courts. OK, so what did the Eleventh Circuit say about Loper Bright, or what did the Ninth Circuit say about Loper Bright, depending on where our case lies, and then trying to bring ourselves into line with both the Supreme Court and what we're seeing out of the circuit that would eventually have jurisdiction over the appeal in a particular case.

So all of them are huge cases, and as you know, they're bubbling through the system. In some of them, like Jarkesy, we've had the Silver Moss case. Or Hirsch Birdman, I know there was a petition filed recently in the Supreme Court on that one. So we are in the position of bystanders in some ways but also part of the conversation because we are given the ingredients. We try to use those ingredients, and then once our work is done in each of those situations, we have to wait to see what the circuits do with it and then what the Supreme Court ultimately does if the issue is nuanced enough that they want to take another whack at it.

Nathan Richman: And you have the odd in our normal court structure geographic remit of covering the whole country when some of the circuits you go to don't and the other trial courts, some don't.

Patrick Urda: Oh, it's one of the really interesting parts of the job because you have to be a circuit watcher even if your case isn't going to that circuit necessarily because I think circuits are very hesitant to go into split with each other. So you want to know what's happening in the circuit in front of you, but you also want to know how is this developing throughout circuits and how might my circuit think about this. These are all important considerations. Obviously, the Tax Court has the additional overlay of we follow our own precedent, which is unusual in a trial court. So you've got to look at Tax Court precedent, figure out what's happening in the circuits, and think about, "OK, and no one really has talked about this new Supreme Court case," and put that together.

So that's why I'm hesitant to say, "Oh, this case or that case has really been the most influential," because all of them are influential. And when something like any of those cases come down, we really have to go through our paces to make sure that we're getting the understanding of the Supreme Court as well as we can, and then trying to apply it in the Tax Court context as much as we can.

Nathan Richman: Is there a number of circuits coming down on the side of a particular issue that will cause you to start rethinking even a long line of cases? The jurisdictionality that circuits are starting to look like they're leaning pretty heavily without any sort of a split, but it is a split with you?

Patrick Urda: Well, I think that it's one of those things where there's no set number, but of course the court has the court conference procedures. So sometimes we will revisit issues. I think that Judge Cohen and Judge Halpern have both articulated in the past in written articles some of the considerations that chief judges often use for sending cases to conference, and one of those is whether a circuit has reversed us or opined on one of our opinions in a way that makes the chief judge think, "This would be good for the court as a whole to talk over."

So we're constantly having those conversations as a formal matter, just in terms of evaluating what cases should be heard. But informally, you talk to your colleagues. It's just like, "Oh, what do you think about this?" So this is a long way of saying there is no set number. I think that we all have informal conversations, but at a certain point in time I think that obviously we'll revisit issues when it becomes the point where it's appropriate. I think that —

Nathan Richman: Momentum can matter.

Patrick Urda: Yeah, momentum can. Though, I will also say that it's a different push me, pull you. Because you have something like Hallmark that came out right after the Third Circuit, I believe, where the court restated, "We are still, based on our analysis of the tax context and structure of the statute, we think that this is a jurisdictional provision." So it's one of those things where at what point in time do you revisit the revisiting? I don't know. That's something where it's a classic discussion amongst colleagues at conference of, "Hey, I've got a case, and I think that we should take it up." And if enough people think let's take it up, even if the chief judge doesn't necessarily think that the time's right, then we'll take it up, and we'll talk about it, and we'll figure out what to do.

Nathan Richman: Another major trend that's been going on have been the easement and microcaptive cases. Any movement, any change in the trend of how those cases are playing out or the stream of them coming in?

Patrick Urda: Well, I think that the stream has lessened, just on the level of most of these transactions seem to be in the 2016 to 2018 range. So at least from what I've seen anecdotally, it seems like there are fewer cases outside of that range. So I don't know what that means. If that's just a blip or like so many data points, maybe it looks this way for a second and then it'll change. But we continue to do a lot of work on conservation easement and microcaptives. Obviously, we don't necessarily drive the train because we are ready for trial when the parties tell us they are ready for trial.

As Judge Gustafson once told me, "If the parties don't have a dispute, I don't have something to resolve." So I try to keep that in mind, and I think many of our colleagues do. So when the parties are still talking, when they still want to discuss settlement, if they're in the Appeals Office , all of these things, we're willing to give them their time. And then when they're ready for trial, we're ready to schedule them. So that's the process that we're following and we're going to continue to follow.

I will say that obviously a number of these cases have been argued recently, and they're often in the Southeast, so that's Eleventh Circuit country. So I do wonder if we're going to get some guidance from the Eleventh Circuit. And of course, that's I think from my time as a litigant, once you get to more data points, you have a better sense of what to do. So my view of this is I'm not sure if it's lessened or where we are in the audit or examination cycle of these. We continue to do our work just as soon as the parties will let us on them, and we'll just have to see what happens with different developments in the Eleventh Circuit, or the Supreme Court, or any other circuits and see if that changes the posture between the parties.

Nathan Richman: Speaking of the parties driving the train, one of the parties before you has just gone through a rather, shall we say, hectic year. All of the changes at the IRS, the 25 percent headcount loss, so many different commissioners in '25, Inflation Reduction Act funding, shutdowns. Have you started to see an effect from the IRS's turmoil on the litigation that you're seeing either coming in or in process?

Patrick Urda: I will say as a trial court judge, I have seen only outstanding lawyers by the IRS. It's the same quality of lawyers that I've seen all along. And whatever's going on behind the scenes, I haven't picked up anything that makes me think that the government isn't being ably represented at all times in front of the Tax Court — and that's what we want. So the types of cases, I'm really not equipped to go into that, but what I would say is the advocacy has remained consistent with everything that I've seen over the last eight years.

Nathan Richman: No noticed change in continuance requests or time to get cases ready?

Patrick Urda: Well, obviously with the government shutdown, as is in every government shutdown, there are continuance requests. But no, the parties — it's tough because sometimes it's who is the wizard. Is it the judge behind the veil that's the wizard? I like to think that the parties are actually the wizard because I don't have any particular insights into them. But what I can tell you is it does not feel like I'm seeing much of a difference between the parties in terms of the litigation that I have experienced over the last eight years. So kudos to both the attorneys for the IRS, and kudos to the attorneys who are opposing the IRS because the standard of work and the professionalism is truly wonderful — and that's one of the joys of the Tax Court.

I remember as a young attorney in Chicago doing a deposition, and an old Chicago attorney objected to every single question I asked just because I'm the young guy and he's going to give the young guy a lot of junk. You see the lawyers in the Tax Court, and there are so many people who look out for each other. And I know people who leave one area of the law or leave government practice — they're welcomed by the Tax Court bar. It does not feel very competitive in the Tax Court bar — collegial, both in terms of the government attorneys as well as the private practitioners. So it's really heartening, and I think that that culture, that culture has been built by a lot of great people for a long time. And so we're really lucky to inherit that culture from the people who have come before us.

Nathan Richman: Any other litigation trends you're seeing? I have to imagine some of the pandemic sorts of credits might start showing up, even though most of the employment retention credit cases, they're mostly in refund position. But I imagine some might show up.

Patrick Urda: Really, I haven't seen any noticeable trends aside from the microcaptive and conservation easement cases, which of course are well documented at this point in time. But I think that looking at our last congressional budget justification, we're still at about 91 percent of our cases being just regular, plain-Jane deficiency cases of some stripe.

So in terms of topics, you always hesitate because I might be seeing something in Albuquerque, and then somebody in Chicago seems something different, and that's the tough position you're in with a nationwide court because, just as I was talking earlier, conservation easements seemed largely in the Southeast. If I had a trial sitting where I was in Seattle and San Francisco, I'd probably say, "Oh, yes, there aren't no conservation easements, there is no flood. What are people talking about?" But if I'm sitting in Atlanta, as I was for a while, I'm thinking, "There are only conservation easements. No one did anything else in 2017 except get involved in a conservation easement transaction." That is the core of our work.

So it's one of those things where I think that it's a little bit more helpful to just broaden out the jurisdictions that we have whistleblower, lien levy, deficiency, where are we? We're still heavy in the deficiency, as we always have been, and then lien levy after that.

Nathan Richman: So you've had your new case management system DAWSON in place for about five or so years — it's not really all that new anymore. How has it been working out and is anybody pining away for the old one?

Patrick Urda: I don't think so. Internally, I will say our dear beloved Blackstone did a good job of getting some basic information that we needed, but DAWSON has been a game changer for the court, and what's been really cool for us is just seeing people pick it up. So I think last year, we're up to about 70 percent of our petitions being digitally filed.

I was anecdotally on a call with some taxpayers for an upcoming trial session, and it was a pro se person representing herself. And I said, "You can bring these documents to the trial session and we'll make sure that anything that you want, if it's admitted to evidence or you want to admit it to evidence, we'll make sure that it gets uploaded." And she's like, "Do I have to? I'd just prefer to put it on DAWSON and just do the digital upload." And I said, "Yes, please. That would be wonderful. Thank you so much."

So I think that it's really a testament to the DAWSON team, Judge Buch who really shepherded it from its very early stages, but we've got amazing people who run it — Chris Holly, Tenille [Lenard], Mike Marcotte, Mike McVicker, our deputy clerk of court for all of our information technology. They're always working and always thinking about how to make this so that the judges have information presented in a way that they can do their job and complete the mission most effectively. But on the flip side, that the litigants have a good user experience so that they can get the information or they can upload things. And I think that as a person who has not had to tangle with CM/ECF in a number of years, and who every now and again hears a horror story or two from my colleagues back in that world, I'm very happy with what we're doing on DAWSON and the commitment of the court to keep on refining, keep on making it better.

Again, the hard thing for us is that we are a court where we have a lot of personal data. So that is something where we take it very seriously. I know that sometimes frustratingly so for some of us on the other side of the podcast mic.

Nathan Richman: We'll get to that in a moment.

Patrick Urda: Oh, good. Yes. But we take that seriously to try to make sure that the public has access as much as we can without compromising our commitment to safeguard some of that data.

Nathan Richman: Before we get to access to the documents in just a moment, any notable, especially public-facing DAWSON updates in the works?

Patrick Urda: I don't think so right this second, and I'm kind of racking my brain. At the end of last year, we had a number of things that were percolating, and we've been trying to make this a more user-friendly experience, both in DAWSON and in the website itself. There was a website redesign, which rolled out right as the government shutdown was ending that we had been working on for many, many months. The name of the game was really trying to make this as accessible for folks who are trying to file something in the court as possible or trying to get information from the court. It's really impressive because I grew up with the classic thing where the three little bars, and you're trying to figure out, "Where can I find that information?" And now the website has been totally redesigned to make it very easy. What do you want to do? And go there.

And I would also say that DAWSON has a lot of the same type of inputs where it's trying to be very accessible because 70 percent of our people when they walk through the door aren't represented and aren't necessarily lawyers. So we want to make sure that those people can take advantage of our investment in this area.

Nathan Richman: As we said, time for access to documents.

Patrick Urda: Oh, man.

Nathan Richman: There have been a couple of movements in the last couple of years for which I am grateful, and I'm pretty sure the tax community is grateful getting post-trial briefs posted and return of requests through email. But the appetite, as you say, is insatiable. We would always like more. Are you working on anything like motion briefs or pre-trial memos that might also get posted online? The sorts of things that arguably much less likely to have bank account numbers, SSNs [social security numbers], that sort of thing.

Patrick Urda: We're always evaluating this. So we're trying to figure out if there — the briefs, as you said, was an important step forward for us because we were able to figure out, "OK, we can give this without compromising some personal data." But while an important step forward, it's also a bit of low-hanging fruit. So there are so many other areas where you think you have something and then you bring together a number of people because you want to have a number of perspectives. And then it's like, "Ah, that presents these problems." So we're still thinking about if there are any other areas.

We are actively considering things, but until and unless we can figure out a way to do this in the same way as briefs. Or as you mentioned, the email records where the judge actually can look and say, "OK, yeah, these are fine. There's no PII [personally identifying information]  in here," or, "I'm comfortable with these being released," then we're just sticking to safety is the name of the game, and I wish that we had perfect redactions. We don't. No offense to our wonderful litigants, but even the most experienced folks miss something. And it's really hard, so I realize that. So we are going to just keep on evaluating things until we find other areas, and then we will let the tax community know if there are other areas that we can give broader public access.

Nathan Richman: So as we start to wrap up, just let's look more generally to the future. What do you see as the biggest issue the court is likely to face in the next year or so?

Patrick Urda: I think that the court always has to maintain good training of its judges and its personnel in all sorts of things. We live in a changing world, and I think that we need to keep up to speed just internally of new issues that are popping up in the legal landscape. We want to make sure that the folks who are supporting the mission, whether they be clerks, chambers administrators, or other folks, get the absolute best training that they get for their job. So that is something that I really feel very strongly about, and luckily we have the wonderful Judge Weiler who is leading with Judge Siegel our efforts on internal trainings.

But just keeping abreast of different developments. Oh, we're seeing this a lot in this case or that case, and then bringing people together and just talking over what's happening in this area of the law. To make sure that, again going back to customer service, we can serve the public just as well as we can by understanding their arguments, or maybe it's a new technology, understanding the new technology. Or if I'm a chambers administrator, understanding, "Oh, DAWSON allows me to do this or that." So really, the court believes in investment and some of that investment then needs nurturing.

So I want to make sure that — my wife is an old ed-tech person. So she worked for the Mexican government, and one of the things that drove her craziest was computers in the classroom, and then the computers sit there and they do nothing. The teachers don't want to use them, the students don't know what to do with them. They're just kind of something for a politician to show off. So she was very committed, instead of spending that money, let's design different solutions that will actually help students understand how to exist in a more digitized world. And I always think about that with the investments that we make. We don't want to make investments just to make investments. We want to make investments that will then allow the judges, the CAs , the clerks, the clerk of court, the operations staff to do their jobs better.

So over the next year, I think that that's what we're going to be focused on, and I think that that's going to be a continual thing that we're going to try to focus on. We are the beneficiaries of taxpayer money, and I take that very, very seriously — that we owe the taxpayer a good product in return for the money that they're giving us. So yeah, I think that that's something that I really try to remember on pretty much a daily basis.

Nathan Richman: With the educational reference, I would imagine generative AI has to be an interesting question, both internal use, and I believe you recently had one of your first opinions discussing a litigant's use of generative AI, or should I say misuse?

Patrick Urda: Yeah. It's one of those topics that's out there in terms of I think that every single person in the country is chit-chatting about it and water-cooling it. Obviously, the administrative office has started looking at it very intently. So we follow what the administrative office is doing because they do such good work in many of these areas. So just like anyone else, I think that the judges on the Tax Court, the people who are the administrative professionals in the Tax Court are trying to get their arms around it because it is a question of trying to see what this technology means for doing the job. And that's the prism how we look through almost everything. It's what does this mean for us to deliver on getting the best, most accurate reading of Congress's action here and applying it to these folks in front of us?

So it's one of those things where it's here, everybody's talking about it. The Tax Court's no different. The judges are making our way through it, and we'll see where the administrative office goes, and we'll continue those discussions. Yeah, we'll see if it pops up in any more opinions. You're always interested when it pops up, whether in our opinions or a trial court opinion, or I assume a circuit court opinion before too long if it hasn't already. So just seeing how different folks go and think about this topic, which quite frankly, it's not many lawyers that have true insights into AI. It's something where we do need to think about precisely because we're not experts in this area. And as the landscape changes, we need to better understand it and better enhance our use of whatever technologies are before us.

Nathan Richman: Well, thank you again for joining us. It's been a very interesting discussion.

Patrick Urda: An absolute pleasure, as always.

David D. Stewart: That's it for this week. You can find me online @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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