The Supreme Court's recent decision in Loper Bright Enterprises v. Raimondo is reshaping the landscape of tax disputes, potentially favoring large companies over the Internal Revenue Service (IRS) in certain situations. The ruling overturns the Chevron precedent, reducing courts' deference to federal agencies' interpretations of ambiguous laws. This shift impacts various IRS regulations, including those on cross-border transactions, electric vehicles, partnership audits, estate taxes, and stock buybacks. "Taxpayers that may have been sitting on the sidelines, waiting to see what happens with the challenges that are out there, may come out on the field now with their own challenges," Kovacev said. The decision to overturn Chevron reflects broader implications for federal regulatory power beyond taxes, influencing environmental, technology, and securities rules.