Lisandra Ortiz discussed the possible impact on the tax rulemaking process of Loper Bright and Relentless, the two cases pending before the U.S. Supreme Court targeting a decades-old doctrine the Court established in Chevron that has governed the federal courts' review of agencies' interpretations of statutes. During a panel at the 2024 DC Bar Tax Conference, Ortiz said she does not believe the cases will result in a sea change at Treasury. Treasury and the IRS already have made significant changes to their processes, especially following the agency's recent losses in legal disputes that found the government violated the federal rulemaking process under the Administrative Procedure Act (APA) in finalizing certain regulations, Ortiz noted. "We've seen enhanced taxpayer participation in the rulemaking process over the last decade, especially over the last couple of years with the rise of APA challenges to Treasury and IRS guidance," Ortiz said.