David D. Stewart: Welcome to the podcast. I'm David Stewart, editor in chief of Tax Notes Today International. This week: retiring a chief.

In April 2024 Guy Ficco took over as chief of the IRS Criminal Investigation division. Now, after two years in the role and almost 31 years at IRS CI, Chief Ficco has retired from government work.

Tax Notes senior legal reporter Nathan Richman caught up with Chief Ficco on his second to last day in the role a couple of weeks ago. Nate, welcome back to the podcast.

Nathan Richman: Always a pleasure.

David D. Stewart: Can you give us some background on the chief?

Nathan Richman: Ficco worked at the IRS since he was a student in the mid '90s before reaching leadership positions at CI, including deputy chief and then, of course, chief.

David D. Stewart: And what sort of things did you talk about?

Nathan Richman: We discussed his background and tenure at CI, some of the programs he worked on as chief, recent trends at CI — especially in light of the 2025 changes at the IRS — and other enforcement trends.

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

Nathan Richman: Thanks for joining us. How are you doing today?

Guy Ficco: I am doing well. Second to last day. Sitting here in my office in D.C., so doing well.

Nathan Richman: Tell us, what brought you to the IRS and CI, and how long have you been there?

Guy Ficco: So, I started in July of 1995 as a student co-op — so, essentially, a paid intern co-oping to become a special agent. And I was in that capacity for about a year, and then I became a special agent in July of 1996. So, I'll end up being just short of 31 years in my government service. I was an accounting student at Dominican University in New York, which is about 15 miles north of New York City. Come from a family of government employees: My father was a New York City bus driver, my older brother was an auditor with the Defense Contract Audit Agency, and my sister was a revenue officer here at IRS. So, kind of had it in the blood and an opportunity actually outside of my sister.

My sister didn't know that I was applying for the position, but it ended up working out, and I was selected and got to spend the first 14 years of my career in New York City. And then I came down to Washington, D.C., in the summer of 2009, and I've been largely here for the last 17 years, though I did go up to Philadelphia for two years to be the special agent in charge of the Philadelphia field office. So, yeah, it's like I said, 30-plus years and feels like a blink of an eye and I was back starting as a brand new employee, and then sometimes it feels like it was five lifetimes ago. So, yeah, I'm excited and bittersweet to be finishing my government career.

Nathan Richman: What has been the most interesting job or case you worked on in those 30-plus years?

Guy Ficco: Well, being in New York City, you get exposed to all kinds of cases, and that I can — I guess I'm still on the job for another day and a half. If you ask me the question in a day and a half, I will tell you that New York City, the work in New York City just exceeds anything else around the country. For the purposes of today, I got to be neutral — so, exposed to a lot, exposed to amazingly aggressive and talented prosecutors at both the Southern District of New York, as well as Eastern District of New York, and just amazing cases. And me getting an opportunity to be involved in all of those. And that's white collar, that's health care fraud, that's tax evasion, that's money laundering.

I spent a year in the El Dorado Task Force, which is a narcotics money laundering task force. But candidly, my agent career will always be marked by the — or most be known for the KPMG tax shelter investigation, which was almost five years of my career. Started in early 2004, and we ultimately had verdicts from the jury in December of 2008. So, as an agent, that's the one that I'll always turn to. It just lasted; it just went forever and ever. And the thing about it was it did almost go five years. And at the end, I was the only person on the original investigative/prosecution team to be there at the end. So, I was very proud of the fact that I stayed there through the whole time.

In my management career, obviously being chief and being deputy chief has been incredible and opportunities to lead, and in some cases lead it in really, really challenging times. But I'd actually look back to — I spent a year leading our special investigative techniques, which is our undercover program. I didn't have an unbelievable undercover background before I took that job, so it was like drinking from the fire hose, but it was really interesting, really engaging, really active work. And I learned a ton in my year leading that group. So, as a manager, I think that might be my most enjoyable time. But as an agent, I would say KPMG.

Nathan Richman: What was the best cover one of your undercovers had?

Guy Ficco: Oh, I'm not giving out state secrets. The one thing I learned very early on is sometimes it's tough to have conversations with people who lie for a living, but it was enjoyable. And the men and women in that program have got amazing ability to converse and make you feel at ease — and then you're 10 minutes into a conversation, 20 minutes into a conversation, and they told their life story. Their ability is fantastic. And I enjoyed having a chance to see that.

Nathan Richman: During your term as chief, you've shepherded several initiatives. The most prominent I can think of at the moment is the CI-FIRST program. What can you tell us about that program?

Guy Ficco: Well, being in this space, working with financial institutions in later years — fintech companies and such, basically filers of BSA (Bank Secrecy Act) information — there's been just a constant desire for feedback. And are they producing SARs (suspicious activity reports) that are useful to law enforcement, as well as intelligence agencies and such?

Nathan Richman: I recall we discussed BSA filings the last time we spoke for this podcast.

Guy Ficco: Yeah. And I think the CI-FIRST was born out of that and just the idea of trying to create a feedback loop and public-private partnerships. There's certainly a number of public-private partnerships that are around that are very important and successful, but we felt with CI-FIRST we had an ability to really create these forums where we were able to get into actual discussions and real feedback as to what was beneficial and what was working and what wasn't working. And we've done that.

And I was thankful enough when Jim Lee was chief and I was the deputy chief, we were able to bring on and hire a woman named Lauren Kohr, who had previously worked with ACAMS (the Association of Certified Anti-Money Laundering Specialists), and she came — and then also community banking for a decade plus — and her background was just perfect to take this on. And we obviously have done the BSA infographics and showing — and certainly a number of LinkedIn posts and other vehicles through the years, but her leading it and taking it out regionally, working with our local special agent in charges across to their partners in private industry has been very important and has really led to the successes we've had, and it's set the wheels in motion for greater successes into the future that I'm sure will be obtained.

Nathan Richman: Any specific plans for the program going forward that you can discuss?

Guy Ficco: Well, as part of the program, there's this offshoot called OFRR (the Optimizing Financial Records Request initiative), which essentially is creating uniformity of subpoenas and summonses across law enforcement. We think that'll be beneficial, as most of the agencies, us included, have utilized some kind of AI platform to help take in and analyze financial records, but to have it in one common format across the different financial institutions would be fantastic. Because the way it's come in — and some of it is just the way that banks have acquired banks through the years and such — but they come into different formats, and having to spend the man-hours and woman-hours — labor hours, rather — just to get those records in a useful format have been challenging for us.

And it's also challenging for the banks because the banks are trying to create different record sourcing and such, depending on who is requesting the information. So, we're leading that. CI is leading that. We're having support from DOJ and others in that effort, but that's an offshoot of CI-FIRST called OFRR. OFRR is the acronym for it. I would say that was something to point to.

Nathan Richman: Any other programs worth mentioning?

Guy Ficco: Yeah. I mean, I think prior to the change of administration, we had signed on to "30 by '30," which was an aspirational goal to have 30 percent of our sworn 1811s be women by the year 2030, and we were well on our way to achieving that. We probably got up to about 25 percent or so of our 1811s. We pulled back on those efforts, but I think that was something that I was certainly very proud of and moving forward on. Just generally, we've taken on such a hiring push in — not the last year, but the four or five years previous to that. And recognizing that the typical IRS CI special agent has changed — well, the type of investigations, the type of records that we're seeing has adapted through the years.

And what I'm getting at is crypto and blockchain. And up until about 2021, we had an educational requirement to be a special agent: You needed to have 15 plus credits in accounting, and then an additional 15 credits in other business classes. And about 97 percent of our special agents came in through that academic requirement. There always was an opportunity to have career experience replace the academics, but it's like 97 percent was through academics. Jim, before me and then myself, we really put an effort in to try to recognize that there are amazingly talented people who were doing great work in crypto and in fintech who don't necessarily have an accounting degree, but had great experiences.

So, we really tried to market the job to those wider breadth of applicants, and we got it to where it was about 70/30. So, we went from about 3 percent to about 30 percent of our new special agents came in through career experiences as opposed to academics, and I think that strengthened our overall ability of agents across the country.

Nathan Richman: This question might be a year or two early, but it would seem like as crypto has been this new bit of information stream that you have to look into, is there some eye also into looking through people's chatbot conversations for interesting evidence?

Guy Ficco: I think your premise is right. It's probably a couple years early, but I have no doubt that we're going to go there. And there's more and more companies operating with AI agents, AI bots, and that's how communications are being generated and stored. So, I have no doubt that we're going there. And I would just also throw up there, in terms of technology, obviously we're a law enforcement agency and we utilize law enforcement techniques, the same as other agencies. I would look to things such as unmanned vehicles like drones that are going to become more commonplace. It already is commonplace in some surveillance in areas that are hard to reach, or for officer safety if we can't get to a certain remote area.

But I think that's going to become more commonplace in the next decade in terms of activities that law enforcement's going to need — to both have flying drones as well as probably ground drones to assist in completing our missions.

Nathan Richman: 2025 was a very eventful year at the IRS. How did the events like all the leadership turnover and the deferred resignation program affect CI?

Guy Ficco: It affected the whole country, and certainly government at large. IRS lost approximately 30 percent of its workforce across all business units. We didn't lose quite as many in CI, in large part because we made a determination — I made a determination — that 1811s wouldn't be eligible for the DRP (deferred resignation program), at least the second, the agency DRP. The first one was a little bit different; that was government-wide, but we didn't lose as many there. We did lose a lot of our non-1811 professional staff. And where we were in a period of growth and expansion and looking at areas where — we had hired the last five years before that, but we hadn't hired for much of the decade before that.

So, we had closed some offices around the country. We were looking to reopen them with the feeling or the understanding — with the plan that we would be hiring and we would be able to put employees in those offices. We had to quickly pivot off of that. And now we're looking across the country. And my successor, Jared Koopman, I'm sure we'll be looking at what offices now, instead of opening up new ones, what offices maybe are not sustainable in the future. So, it's really changed the whole plan for us in terms of our staffing goals here over the next few to several years.

It also, in terms of our work, we don't get as much today as we did 10 or 15 years ago or 20 years ago from fraud referrals, but we still get a significant amount of our investigations from fraud referrals. And I mentioned that the impact the DRP and such had on CI — it had a greater impact across some of the other business units, notably SB/SE and LB&I, and some of those potential agents and revenue officers who would be completing and doing fraud referrals, those aren't happening at the level they were, either. So, I anticipate the number of those type of investigations is going to change, as well.

So, it's going to require us to pivot a little bit and ensure that we have identified really leveraging data as to where we should be and what type of investigations, and trying to mirror them up to the extent we can with the Department of Justice. And that's Department of Justice nationally, but it's also, and maybe more appropriately, the local U.S. attorneys that are working with my local SACs to ensure that we're working the cases that they want to see, that they want to spend resources on to investigate and prosecute. So, it certainly had a major impact on how we operate and how we are going to operate in the future.

Nathan Richman: Speaking of the Department of Justice, they've also been going through a lot of changes up into, including early this month, where first there was the tax division, and then it was split, where part of the tax division went to the criminal division and part went to the civil division. And then, just most recently, the part that went to the criminal division is now going to a new National Fraud Enforcement division. What have you seen and what do you anticipate seeing at CI from the Justice Department changes?

Guy Ficco: Well, I saw the memo from a couple of days ago from Acting Attorney General Todd Blanche. Candidly, I have not had an opportunity to have any discussions around that, and so I haven't absorbed what the latest changes might do to impact operations. Prior to that, when criminal tax was operating under the criminal division, really hadn't seen much changes; we were still functioning, except that there were different delegation orders and such that had to be signed in order for us to refer and send information back and forth.

But other than that and the understanding that that section now has lost a number of personnel, as well — so that's impacted some of the time and getting things turned over and such — other than that, really haven't seen many changes to our operations up to this point. It'll be interesting to see what happens now with this new directive, this new national fraud division that has been created that tax is going to go under.

Nathan Richman: So, up until, say, the end of March, the biggest change was losses of tax prosecutors more so than the organizational changes.

Guy Ficco: Yeah, I would agree with that. I mean, anytime you go through, in this case, tax section, tax division, tax action, went through changes, there's always some feeling out and some evolution that happens. And I'm sure if you asked any of the attorneys there or the leaders there, they'd be able to give a more colored answer as to some of the nuanced changes that they're going through. But from my seat, really it's just been the decreased number of attorneys, as well as probably their professional staff. That's probably been the biggest impact.

Nathan Richman: Moving on from personnel and structural changes, what impact have you seen from any of the new administration's priorities?

Guy Ficco: In CI last year, I think it's been widely reported that we had a number of agents who were assigned to assist with title 8 operations, which is certainly a priority of this administration. We had up to 250 special agents going on these operations across the country, and we did it in a manner that in very few instances did someone go off on a longer-than-two-week detail to do these title 8 with DHS. We were trying to rotate so that agents would still be able to keep their inventory — so, left that largely in the hands of the special agent in charges to work on those assignments.

So, with that, though, there are certainly these 250 agents, and their hours are being utilized on what I would say would be non-core-mission IRS CI activities. So, that has certainly impacted our investigations. Just D.C. and Memphis, we'll just say we had resources — I think we were up to 24 a day in each of those locations, as well, and that also would be on a couple week rotation. So, I think that the combination of those efforts to support the administration has definitely pulled away some of our core mission time.

Now here we are, it's April 9, happy to say we're pulling out of title 8 activities, of all scheduled activities right now, and we will be out of them if not this week, next week we'll be out of our title 8 activities. We may still support an individual operation if there's a need for us to support, but we'll be out of that, and we'll be out of D.C. in April and be out of Memphis in May. So, we'll have those agents' ability to be fully engaged back on core mission, and I think that'll be beneficial to us. I think you've read and maybe reported on the benefits fraud and the importance being impressed upon that by Secretary Bessent and the president.

And we certainly have been very engaged in the Minnesota, the Feeding Our Future case, over 80 indictments in that case, that CI was on the case and still have significant resources there, as well as looking at similar type frauds around the country. And I think that would've been a traditional — well, it was. I mean, we were engaged prior to this administration on that Feeding Our Future investigation, but I think it's taken even more of an importance, and our agents are well equipped to handle it.

Nathan Richman: Speaking of some of the time away from core-mission cases, has that had an effect — or a substantial effect, if you prefer — on your ability to pursue complex and sophisticated cases like tax shelter schemes or dark net market take-downs?

Guy Ficco: I think we are still in those spaces and we are still looking at complex promoter investigations, tax shelter investigations, as well as complex crypto investigations and decentralized finance and dark net marketplaces and such. I think there's been — I'm sure there's been an impact because those agents in those cases have certainly been involved in these other priorities, but I think we've been able to manage that, and I think we still are heavily involved in those cases. I think one of the challenges becomes we're an investigating agency, so we need the Department of Justice to prosecute our cases.

And we talked about tax division earlier, but some of those cases go right to the U.S. attorney's office in the nontax arena. They're down resources across the country in a lot of the U.S. attorneys' offices, and their priorities — they have to set their own individual priorities, as well. So, some of our more complex cases that maybe would require multiple AUSAs (assistant U.S. attorneys) or additional resources, they may not be supported at the same rate by the DOJ because of those factors. But I think, from an agency standpoint, I think we're still there.

Nathan Richman: You might not have as many grand juries to use or for use in the same sorts of cases because of DOJ headcount and priorities.

Guy Ficco: Well, that, and the U.S. attorney may decline, or their section chiefs and such may decline, to being involved in some of our investigations because they don't feel that they're going to have the proper resources to support it.

Nathan Richman: Earlier you mentioned some of the new technology that you're looking for your special agents to be aware of. One of the things that seems to have come even a little before that is all of the social media. I've heard you guys talk about how posts are open-source intelligence. It's publicly out there; you don't even need a subpoena or a summons. You can just look there and see if somebody's reporting something that might be useful in a case against them or useful for potentially opening a case against them.

There's also been more recent discussion about a growing trend where scam purveyors are purveying their scams using social media — people publishing TikTok videos, posts saying, "All these reasons you don't need to pay your taxes." Has CI or the IRS adjusted any policies or approaches, given how many people get their news from social media, to address this evolution of tax scams on social media?

Guy Ficco: That's a very challenging area, right? Social media — and Nathan, maybe you're more up to speed than me, but it seems the way people, particularly younger generations, get their sources of information is somewhat foreign to me. I've personally never been on TikTok, but I do know that that's a very valuable resource for a lot of people in the country.

So, without giving away some of the state secrets, I'll say last year — I think it was last year; the years kind of run in to me — there was a challenge at one of the taxpayer experience days where there were hundreds and hundreds of people who had, I guess maybe thousands of people across the country who had seen a video that was purporting for a way for people to collect money from the IRS by showing up at these days with doing certain things that they had learned on video. And it wasn't true, and we got overwhelmed in some of our offices.

And it was a lesson for us in CI, but really across the whole service, that we needed to ensure that we were monitoring, to the extent we could, these different sites, because they were informative, and the public was locking into things they were learning. So, we certainly — and we call it open-source intelligence, as you described — we certainly do monitor and look for information that could potentially either — there's a couple buckets that could lead to a new investigation, it could just be general misinformation that's being reported out.

In some cases, fugitive — we may be trying to find a fugitive and we don't know where they are, and they'll post something on social media, which will immediately identify where they are, and then where that allows us to go ahead and affect the warrant that they're fugitive from. So, it's something that we've moved in that direction. We have more room to go, and I think this is probably going to keep evolving over — I don't know if it's ever going to stop evolving, but it's certainly going to evolve over the next couple of years, about how people obtain their information and what gets posted. And us and every other law enforcement agency out there has to be aware of it in calculating that into our investigative plans.

Nathan Richman: Do you think the companies have any responsibility to address the scam misinformation on their sites?

Guy Ficco: I've made a career out of not opining on stuff like that; I let the congressmen and congresswomen and senators and such weigh in on that. If you ask me in about 48 hours, maybe I'll give you a bigger answer. But I would say the proliferation of scams in this country and around the world is just scary. And I hope that as a society, some things happen because it's just really, really scary, and the technology's getting so good to fool people and defraud people that it's — I don't know where it ends, so it's a scary time.

Nathan Richman: Another area that we've been following is the cryptocurrency enforcement push. Recently, there's been the first charge and sentence for Frank Ahlgren, and then there has been the meteoric rise and fall of the case against Roger "Bitcoin Jesus" Ver. Are any other notable cryptocurrency legal-source income tax cases coming soon, I should say?

Guy Ficco: Yeah. I mean, obviously through the years myself, and I think Jim before me, had previewed that there were going to be more cases in this space. Beyond those two, there was an NFT case in Pennsylvania, a non-fungible token case that was prosecuted last year, I believe. I think that there are certainly, with the 1099 digital assets coming online this year, that is going to add some additional information and intelligence for the agents. We have the summons information from a couple years ago, so I think there'll be opportunities to identify noncompliance and whether or not those rise to criminal prosecutions or are handled in a civil treatment.

I think that'll remain to be seen, but I'm not going to sit here and tell you that "give me two months, wait a few more weeks, and we're going to have a push on April 15 in crypto tax investigations," because I don't think that's happening.

Nathan Richman: The new administration has made its interest in crypto very well known. Has that had any effect in this space?

Guy Ficco: Private investors or in general, or from a law enforcement perspective?

Nathan Richman: I know that they're talking up the private investor side. Has that leaked into the enforcement side?

Guy Ficco: I think beyond CI, as I mentioned earlier, because we partner with the Department of Justice, I think on some of these investigations that we're looking or some of the things that we're generating that we think we've got outliers or data or even a whistleblower that is saying something, the conversations with DOJ, they have to get comfortable with our investigation and potential prosecution. So, I think it's certainly, it's a factor that they — the DOJ, U.S. Attorney's Office or Crim[inal] Division, whoever we're working with — it's a factor that they would, I'm sure, take into consideration when deciding whether or not to support these investigations, as we do as well.

And so, I think we don't spend our time, we don't put resources on cases that are not going to get prosecuted and not drive deterrence because at the end of the game, our role here in criminal tax enforcement is to drive deterrence and drive compliance to lower the tax gap. So, any factor that's out there that could impact an investigation's ability to become successful, I wouldn't be doing my job, my due diligence, if I didn't take it into account.

Nathan Richman: In 2022 we heard a lot about the joint strategic emerging issues team and IRS-wide initiative to track emerging issues, abusive transactions, and coordinated enforcement strategies, but we haven't heard much in the last couple of years. Can you tell us what happened to it?

Guy Ficco: The JSEIT. Yeah. Well, I'm not sure if the JSEIT is completely defunct, but it certainly is not currently operating, at least not in the manner that was being talked about a couple years ago. If you recall, prior to — well, in 2024, there was a reorganization at the IRS that created the chief tax compliance officer. The first one was Heather Maloy in CI. It was part of the CTCO, as well as SB/SE and LB&I and TE/GE (Tax Exempt and Government Entities division) and others. And that was really kind of a successor to the JSEIT because then this was allowing the business unit heads like myself to be engaged on this multi-BOD compliance strategy.

And that structure carried forward until January of this year, when the CEO Bisignano announced some changes there and CI becoming a direct report up to the CEO. But CTCO is still there. So, without CI — and that is actually the position that Jarod Koopman has been acting in for the last six or seven months. And he'll continue to, actually, even when he becomes chief, he's still going to maintain acting over that role for at least a little bit of time until a replacement is selected. And that role, part of that is, and part of our conversations have been, how do we work together across compliance and enforcement? How do we work together to drive compliance to lower the tax gap?

And even efforts, which you may ask me about here in a minute, about updating the voluntary disclosure program is really part of that discussion across CTCO. What can we do that will get more taxpayers into compliance to really lower the tax gap? So, the JSEIT itself may not be there anymore, but we're onto the successor organization, which is still trying to accomplish some of the same goals.

Nathan Richman: No wonder you're chief of CI, because you are a very good investigator. I was exactly about to bring up voluntary disclosure.

Guy Ficco: Yeah.

Nathan Richman: So, you recently announced the IRS's plan to amend the voluntary disclosure procedures after a notice and comment period, and that period has just closed. But first, what prompted the decision to both amend and amend with notice and comment?

Guy Ficco: Well, as you've seen me and others at different conferences and getting a chance to engage with practitioners, it was a common theme that many taxpayers didn't want to come in because of, if you want to say flaws or just nuances to the existing VDP, and had numerous conversations with Erin Collins, our taxpayer advocate, as well as others, and felt the timing was right to revisit where we were.

And being that it was generated from having different conversations with practitioners and such across the country at these conferences or some other forum, it just felt like it was the fair thing to do that it shouldn't just be the practitioners who know me who get a chance to comment; we should open this up to everybody. And we did that, and the period has now closed, and I know the team is evaluating the information that's come in. I won't go into what that evaluation looks like, it won't be me to sign off on it, but I can say that some of the comments have been really helpful, and I think they are going to lead to some modifications to what was drafted and what was sent out there in December.

And I think that's healthy. I think it's healthy to look at programs like this every — I don't know if it's every couple of years, but at least some kind of cadence so that we can make changes when appropriate and sometimes reinforce things when they're appropriate, as well. So, I think it's going to be good. And I think that Jarod as the chief as well as CTCO, he's going to have a significant role in proving whatever ultimate changes are ultimately made.

Nathan Richman: Well, thank you so much for your time. Just one last batch of short questions: Why did you decide to retire now, and what's next?

Guy Ficco: I think with law enforcement, you have the ability to retire after 20 years and 50 years old, or 25 years at any age. So, for me, I've been eligible for about five years, and I think you're always looking at, "OK, am I the right person to keep leading? Am I tired? Do I still have the energy to do this? What's the right time to go?" When I was selected, Commissioner Werfel was the commissioner, and I had — Doug O'Donnell was the deputy commissioner, and I had committed to two years in the role, which was April 1 of '26. So, just last week I hit my two-year mark. So, there was importance, even though no one else was still around, it was important to me to fulfill that commitment, and I was able to do that.

And I think the way things shaped up and being able to have our agents pulled back from those other areas, the administration priorities, but other areas like title 8 and D.C. and Memphis, I think the timing is good, and I'm excited to sort of punch the clock one more time tomorrow and take a little bit of time and try to have a little work-life balance. I don't know exactly — I have a pretty good suspicion of what comes next, but I don't know for sure, but I'm going to take a little bit of time and I'll hopefully be able to announce something in the not-too-distant future. But I do know I want to stay engaged in the ecosystem, the tax ecosystem, the AML (anti-money-laundering) ecosystem in some capacity.

So, I think being a preview, I think those are the areas that I'll probably be in.

Nathan Richman: Well, thanks again. And it's been a pleasure chatting with you.

Guy Ficco: If I can just add, this is probably, I don't know, the third, fourth, fifth time that we've had an opportunity to talk through the years, and I have enjoyed it. Just want to thank you for your good coverage. And I don't mean good as always favorable, I mean just being good in comprehensive coverage of CI, and I appreciate that. I think it's a good give-and-take, and I appreciate the way you've reported through the years. So, thank you.

David D. Stewart: That's it for this week. You can follow 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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