In Richard Rubin's recent Wall Street Journal article "America's New Tax Mantra: 'The IRS Isn't Going to Catch Me'," firm partner Josh O. Ungerman provides insight into the practical effects of declining IRS resources on tax controversy. Mr. Ungerman notes that overwhelmed IRS Appeals functions are creating significant delays for taxpayers seeking resolution, explaining that "it's difficult to get your opportunity to make your case to the appeals officer because there's so many people in front of you," highlighting how resource constraints are reshaping the audit and appeals landscape.