Robert Kovacev discussed the Supreme Court's recent Loper Bright ruling and its profound implications for federal tax law. The decision overturns the Chevron doctrine, shifting judicial review of Internal Revenue Service (IRS) regulations from deference to independent scrutiny. Kovacev emphasized that this change will likely increase litigation challenging IRS regulations, particularly those under statutes like the Tax Cuts and Jobs Act of 2017 (TCJA) and the Inflation Reduction Act of 2022 (IRA). He predicts heightened scrutiny of regulations affecting areas such as Corporate Alternative Minimum Tax (CAMT) and transfer pricing, where regulations have historically filled statutory gaps. Kovacev anticipates increased complexity in tax disputes and suggests taxpayers reevaluate positions previously deemed unchallengeable under Chevron. He noted, "Look back to see if there is an issue where there's a regulation which is hurting us. We are following it because we didn't think we had a chance to challenge it because of Chevron. Now things are different."