In Law360, Robert Kovacev discussed Liberty Global's economic substance doctrine challenge, an important federal tax case to monitor in 2025. The Tenth Circuit Court of Appeals is set to rule this challenge to the Internal Revenue Service's (IRS) interpretation of the economic substance doctrine, which allows the IRS to disregard transactions aimed solely at tax avoidance. If the court sides with the IRS, it could lead to a more aggressive application of this doctrine, potentially impacting even routine tax transactions. On the other hand, a decision in favor of Liberty Global could reinforce the argument that not all transactions need a non-tax business purpose. Kovacev emphasized that this case "could be a harbinger of things to come," either strengthening the IRS's stance or reinforcing the taxpayer's argument.