Professors Bridget J. Crawford of the Pace University School of Law and Anthony C. Infanti of the University of Pittsburgh School of Law discuss viewing the U.S. tax code through a feminist lens.
Listen to more Tax Notes Talk episodes from our critical tax theory series:
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This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
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Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Professors Bridget J. Crawford of the Pace University School of Law and Anthony C. Infanti of the University of Pittsburgh School of Law discuss viewing the U.S. tax code through a feminist lens.
Listen to more Tax Notes Talk episodes from our critical tax theory series:
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Welcome to the podcast. I'm David Stewart, editor in chief of Tax Notes Today International. This week: feminism and taxation. Here in the U.S., while one of our founding documents recognizes certain unalienable rights, the authors and following generations s eem to have had trouble grasping who all that should apply to. This week's episode is part of a series we've done examining how tax rules affect marginalized groups. We'll include links in the show notes to our previous episodes on the intersection of tax and racial inequality, LGBTQ rights, and diversity in international tax policy. But now more than 100 years after the women's suffrage movement set the scene for modern day feminism, the rise of social media and events like the Women's March and the Me Too movement have elevated the discussion around feminism's impact on all aspects of life, including taxation. Joining me now to talk more about this is Tax Notes reporter Carolina Vargas. Carolina, welcome back to the podcast.
Carolina Vargas:Thanks Dave. Glad to be here.
David D. Stewart:Now I understand you recently spoke with two professors about this issue. Could you tell me about your guests?
Carolina Vargas:I spoke with Bridget Crawford and Anthony C. Infanti. Bridget is a professor of law at the Elizabeth Haub School of Law at Pace University, where she teaches taxation and feminist legal theory. Anthony, professor of law at the University of Pittsburgh's School of Law, teaches courses in tax with a focus on the impact of tax laws on marginalized groups.
David D. Stewart:Alright, could you give us an overview of what you discussed?
Carolina Vargas:We discussed the intersectionality of feminism and tax and how it has impacted tax law throughout history and continues to do so today. We also talked about how we can work to reform the tax system with that feminist viewpoint in mind.
David D. Stewart:Alright, let's go to that interview.
Carolina Vargas:Hi, Bridget and Tony. Thank you so much for joining me today.
Anthony C. Infanti:Thank you for having us.
Bridget J. Crawford:Thank you.
Carolina Vargas:So my first question you both is how is taxation a feminist issue and what does it mean to use a feminist scope?
Bridget J. Crawford:I think we should start first by defining what we mean by feminism. And I think Tony and I, and many others take a broad approach to what that term means. Obviously, feminism as we understand it in the 21st century, has its roots in the 19th century women's rights movement carried over into the 1970s. And so it's a movement with political origins that specifically focused on advancing women's equality. But as Tony and I approach it, we understand it as a broad social justice movement that's concerned with equality for all people and many different issues that have been historically marginalized. So in terms of what it means to take a feminist perspective on taxation, certainly that perspective has a particular interested in women's equality, but equality for all sorts of other groups as well, including racial minorities, LGBTQ people, disabled individuals, it also encompasses broad perspectives on the environment and other issues. So I think our approach to feminism is that it is a very, very, very broad tent with a particular historic background.
Anthony C. Infanti:Yeah. And Bridget has it exactly right, because one of the things that you can't ignore is that there are intersections among all of these groups. There are women in racial minority groups, there are women in the LGBTQ community, gender surfaces in all sorts of different ways in all of these different groups. And when we're thinking about looking at tax and law from a feminist perspective, especially when you take such a broad and capacious view of what feminism means, it's important to remember that tax law is a reflection of our society and who we are and what we value. And bringing social justice viewpoints into that is really important, especially as we come to a time where we see more and more being run through the tax system. We have all sorts of social programs now being run through the tax system, the new changes to the child tax credit that they did for this year. Things like that, that would normally in other countries probably be run through direct programs are being run through the tax system. So it's really important to think about the social justice implications of all of these different programs, as well as kind of the basic structure of the code, because the basic structure of the code also implicates social justice questions.
Carolina Vargas:Bridget, you said that this had been an issue for a long time. Could you give me some example of cases in the past of why it was important to look at this through a feminist perspective?
Bridget J. Crawford:Well there we go back to the first wave of feminists and the declaration of sentiments in 1848, where Elizabeth Cady Stanton and others articulated women's exclusion from voting as a form of taxation without representation, borrowing that historic language from American history to bring those issues to the fore. But the contemporary focus on feminism and tax really started with an article written in 1971 by Grace Ganz Blumberg, now a professor emerita at UCLA Law School. And she wrote an article in the Buffalo Law Review called"Sexism in the Code: A Comparative Study of Income Taxation of Working Wives and Mothers," looking at the way that women's participation in the marketplace for labor historically has been disadvantaged and the disincentives for women work. So there's a longer trajectory of tax rhetoric that is super important and then we would mark formally the focus on gender issues and taxation with that important article by professor Blumberg in 1971.
Carolina Vargas:And how has this impacted the tax law, as we know it today?
Anthony C. Infanti:The thing with that critical tax theory, which is kind of the broad umbrella that we think of covering feminist perspectives on tax, critical race perspectives on tax, queer theory perspectives on tax, hasn't had as much of an impact on kind of the direct tax code as any of us I think would like. It's just now really starting to kind of seek more into the conversation. We're starting to see more folks outside of the academy, focusing on these issues and this great podcast series that we have here is focusing on this. We're seeing more think tanks focusing on it, we're seeing folks in Congress focusing on, and we've had hearings on kind of racial impacts of taxation last year. And so we're starting to see some more movement. We haven't seen enough I think o f a direct impact on the shape of the tax laws as any of us would like yet, but hopefully more will be coming.
Carolina Vargas:Great, so speaking of changes that need to be made, what are some of the necessary changes to the tax code or the tax viewpoint that could be beneficial for understanding feminism in taxes?
Bridget J. Crawford:Obviously there's no one feminist viewpoint about anything, but one issue that feminist scholars have debated for a very long time is the joint filing system for income tax returns. Whether it is reasonable to see spouses as one economic unit and the way that disadvantages spouses who are the lower income earner or does not participate in market labor at all. So that's one salient issue. And I think Tony has some more at the forefront of his mind.
Anthony C. Infanti:Yeah. I mean, definitely joint filing. I mean as Bridget said, there's definitely different perspectives on kind of what a feminist viewpoint would dictate in terms of the actual solutions that are adopted. And I think when we talk about joint filing versus individual filing, that's one that hopefully should kind of crossed the lines in the sense that the way that our joint filing unit is set up. Historically there have been marriage penalties for women, typically women, it's the secondary earner, but historically the woman has been the secondary earner in different sex married couples, from them participating in the labor force because their wages would be stacked on top of their husbands, in essence. And they would be taxed at the highest marginal rates of the couple. So that creates a disincentive for them to go out to work. That was tamped down somewhat by the Tax Cuts and Jobs Act, but kind of married with those tax disincentives have always been tax bonuses for married couples that had just had a single breadwinner, which is historically that kind of like 1950s, Ozzie and Harriet view of the married couple, where the husband goes out to work and the wife stays at home. And I think we would probably all agree that we don't need to be spending money to encourage a certain kind of family, particularly one that's tied to kind of a nostalgic 1950s view of what a married couple should look like. That we should be acting in ways that allow people to choose whatever kind of family arrangement that they would like rather than privileging one arrangement overall others. And then there are lots of other aspects of this as well. I mean, you can go from the very rhetorical to that things that have real financial impacts on people. One thing that's kind of rhetorical, but still important is the fact that we do not use gender neutral language in the Internal Revenue Code. Lots of countries have moved to gender neutral, statutory drafting. We have not. So the taxpayer in the code is he, him, his, always. It's very rare to see she, but when you do see she, it's always as the wife of them in the code and you see that mirrored in the regulations as well. And the regulations, a lot of the regulations are older and they tend to trade in what you would consider to be gender stereotypes about what married couples look like. You'll see, there's regs with examples of, oh, well, if you make a gift to a wife like a business gift to a wife, well that really is a business gift to the husband, unless you can prove that the wife has her own independent relationship and that's independent business relationship because say she's in a partnership with the husband running a business. And so it's those kinds of stereotypes, stereotypes about when you can deduct travel expenses well, the husband is the one that's out traveling for business. And if the wife comes along, you have to prove why the wife is there and that she's doing something business- related. And the regs are written in that kind of language and then expanding it kind of when you think of gender, not just as gender, but also thinking about the gender overlaps with sexual orientation as well. You see that in addition to everything that is going on. So after the Windsor decision, when the Supreme Court said that,"same-sex marriage had to be recognized for federal tax purposes and other purposes of federal law." The IRS went in and changed the regulations, but rejected suggestions that the regulation specifically referenced same-sex marriage. Instead, what they decided to do was say that every time they use the words, husband and wife in the code, they mean anyone who's married to anyone else, because according to the IRS, if you had to mention same-sex couples that would go against their attempt to try to eliminate the gendered aspects of the code. And it's like, this is crazy. How can you possibly say that you were working towards eliminating the gendered aspects of the code, where you're defining the words, husband and wife, which are gender terms and basically kind of erasing same-sex couples when you're supposed to actually be recognizing same-sex couples. So, I mean, you see that in the very rhetorical aspects of things. I mean, you also see it kind of every day money kind of things when you think about how we deal with childcare, which is an important issue for women when they go out to work. We have now changes just for one year with the pandemic, to the child tax credit and to the dependent care assistance credit. They both could have been expanded, who gets covered, how much you get, but still those are only temporary. And then when you think about the dependent care assistance credit and also that exclusion for benefits under dependent care assistance plans in the code, both of those to my Monday, one of the big things that they missed in thinking about those is how they actually work, how people actually get them, because you think about what's happening, you have a credit. So when you're talking about dependent care assistance credit, that's basically helped for people who are going out to work and need childcare. And so this is the code's way of helping to defray that because we don't have a national program to pay for childcare. And so what happens is you get a choice between a credit and an exclusion. And just generally speaking, the way that these things work is that lower income people will prefer the credit, the way that it's structured and higher income people generally prefer the exclusion. And I was talking to my own classes when we cover this stuff in taxation of the family, about how tax design is important, thinking about how this actually gets delivered to people, not just we're trying to give benefits, but are we actually getting the benefits to the people when they need them? And you think about the dependent care assistance credit, the one that generally is preferred by lower income people. Well, that's a credit, there's no way of getting that in advance. And now they've changed the child tax credit, so it's paid in advance every month. They did not do the same thing for the dependent care assistance credit. So now you're paying for your childcare all year long. When do you get your help from the government? The following April 15th, when you file your tax returns. So you've already had to pay for your childcare all year long and then you're getting it. But when you think about the exclusion, which generally higher income people take advantage of, that's usually done through flexible spending arrangements. That's how I took advantage of it when my daughter was young and we were using childcare. With that, they take money out of my paycheck every month, as soon as it was taken out, I could put in for reimbursement for the amounts that I paid for childcare. So I'm getting real time money through that flexible spending arrangement to help cover the cost of childcare. OK, well, who really needs the real time help? Privileged folks like me who teach at university or folks who are living paycheck to paycheck and really should be as an independent care credit. That's a tax design issue that seems to have escaped Congress, that they don't seem to focus on that and the fact that that's a real issue for working women and that we should be thinking about that. And so there's lots of aspects of this and I could go on like all day long. So I'll just stop there with all the different ways in which kind of gender intersects with the code and how we could make it better.
Carolina Vargas:You also talked a little bit about how caretaking is a very big gendered issue in the tax code. Could one of you talk to me about the Moritz case?
Bridget J. Crawford:So this is a fantastic case and many of us think of this as Ruth Bader Ginsburg's first equality jurisprudence case. In 1968, there was an unmarried Colorado man named Charles Moritz. He took a deduction on his income tax return for expenses paid and caretaking for his elderly mother who lived with him. At that particular time, the applicable position of the Internal Revenue Code allowed taxpayers to take deductions for dependent care expenses. But that was available only very interesting, to a woman or a widower or a husband whose wife is incapacitated or institutionalized, not for a single man like Mr. Moritz. So the Tax Court upheld the denial of that deduction. And luckily for Mr. Moritz, the great tax lawyer, Martin Ginsburg happened to be reading this tax advance sheet and presented it to his wife, Ruth Bader Ginsburg, who according to a speech that Martin Ginsburg made years later said,"oh, I don't read tax cases get out of here." But she read the case and rapidly agreed that the two of them would represent Mr. Moritz on a pro bono basis. They appealed the case to the Tenth Circuit and the Tenth Circuit reversed the Tax Court finding that this was discrimination on the basis of a sex. And as it turns out, the Supreme Court decision in Reed was running alongside that case at the same time, although the Ginsburgs started their work on Moritz first, the Reed decision came out first. And in fact, the Tenth Circuit relied on the Ginsberg, Ruth Bader Ginsburg's work in the Reed case. So Moritz to me is one of those foundational underappreciated cases that really made it clear that the tax code had gender discrimination baked right into it. It said right there, this is only for women and this is for men who were either widowers or who had wives who were incapacitated. And thanks to Ruth Bader Ginsburg and her brilliant tax attorney husband, Martin Ginsburg, that is no longer the law.
Carolina Vargas:Great. Tony, anything to add?
Anthony C. Infanti:Yeah. I mean, the only thing I would add is that it just goes to show you once again, kind of jumping off of what Bridget said, how the way that we draft our tax laws sends messages about who and what we value. It's really saying when you look at that, who could get that deduction at that time, they're giving you a sense of who they think it is that is needing help with taking care of other people. The people who supposed to be taking care of people are number one, women. That's what it's sending out. And men should only be taking care of other people. If the woman in their life has either passed away and can't take care of them or is incapacitated and can't take care of them, men, they have no business taking care of anybody, which that definitely sends messages to society about what we value, what we expect, what we think is appropriate or right. I mean, to my mind, completely wrong messages, but it's sending messages. And that's part of what we need to think about when we're thinking about, it's not just a matter of discrimination against a certain person. It's about what are we saying? What are we saying as a society about who should be doing what. What do we value? What are different people's roles in society? I mean, people don't think of tax usually in that respect, people usually think of tax as a very economic kind of an issue. It's just, how much do I owe the government? How can I minimize that amount as much as possible? They're not thinking about tax in the way of, OK, who are we giving money to? Who are we supporting? And who are we not supporting? Because those decisions send clear messages about what we value as a society. And we should be questioning that, we should be aware of it and questioning our congressmen, questioning the IRS, questioning whoever about why it is that this is the case.
Bridget J. Crawford:And also questioning why the tax code cannot even bring itself to talk about same sex couples that I think is an embarrassment to the government, that it won't even take the basic step of moving to gender neutrality, hiding behind this very old fashioned argument that'he' means, oh, it could be a person of either gender. It's time to move the tax code to the 21st century and recognize the glorious diversity of human affectional relationships.
Anthony C. Infanti:Just to underscore what Bridget does said. I mean, the thing that's crazy about that is that they rely on the Dictionary Act. So there's, there's actually an act called the Dictionary Act that says that throughout federal law, like he includes she, him includes her. It doesn't go in the other direction. It doesn't say she includes him. It only goes in one direction. And so that needs to be fixed, but what's even kind of more appalling to my mind is the fact that the Dictionary Act doesn't prevent the IRS from fixing it's publications to refer to just spouses or even to change it's examples to, I don't know, switch them up a little bit once in a while so that everyone's not heterosexual, but they don't. I mean, when you go through the publications, you'll see where they're referring to married folks. Sometimes it's kind of just married folks in general, but when they're talking about specific people, it's always different sex couples always. And so you don't see that kind of acknowledgement that the other exists. There's nothing that prevents the IRS from changing that, like absolutely nothing, except for them getting out of their own way to do it.
Carolina Vargas:So some of the articles I was reading was discussing a little bit about how even terms that were gender neutral usually favored men or were directed for men. Could you talk to me a little bit about that?
Bridget J. Crawford:Oh, this is so important. Wendy Gerzog, who is one of the most brilliant estate and gift tax scholars we have, wrote an article in 1995 talking about the estate and gift tax marital deduction. And what's known as the QTIP trust, the qualified terminable interest property, and to make a long story short, this is over simplifying, the transferor can get a full marital deduction for transfers in trust that the transferor still controls a lot of the strings over. In otherwise, typically the man would transfer assets to a trust and as long as the wife is getting income, at least annually from that trust, even if she has no right to direct the disposition of the property on her death, husband still get some marital deduction for that, just as if it were an outright transfer. Now it doesn't say husband and wife in the code that's gender neutral, but the fact of the matter is the majority of wealth in different sex relationships is held by men. And at the time this provision was written, most certainly that was even more true than it is today. So who benefits, who benefits from those provisions? It's the wealthier spouse, the wealthier spouse is more likely to be the man and statistically speaking, the men are more likely to die first compared to their wives, if in different sex relationships. So it's really a way for men to continue to control the disposition of property at their wives subsequent death, even though the code is written in a gender neutral way.
Anthony C. Infanti:Right. And I think that Wendy did a fabulous job of also minding the legislative history and stuff to show that that's kind of what was in mind, was that it was men who would be controlling the property. And it just goes to show kind of how the tax code is built on top of all of the assumptions that people have from living in society. It doesn't live on its own off in some rarefied atmosphere. And so just because it doesn't mention something doesn't mean that that's not what it's targeting. And as we talked about earlier with the married couple as the filing unit, and you're thinking about the joint return and the incentives that it creates, it's generally not thought that it's creating an incentive for the husband to stay at home because that's historically not what has happened. That the wife is born a disproportionate burden in terms of that work in the household and taking care of children and things like that. And when you have that kind of an atmosphere it doesn't, it's not hard to fill in the blank sometimes. So the marriage penalty historically has not just been about the tax rates that apply. I mean, there's other provisions in the code that also feed into the marriage penalty. And there's lots of provisions in the code where the only way to get, say a deduction, is if you file a joint return, if you're a married couple, but then they don't go and say double the deduction. So you think about like educational loan interest, you can deduct the limited amount of educational loan interest, to my students, whenever I talked to them about it, a disappointingly small amount of educational loan interest. And if you're married, you have to file jointly to get that. But if you get it, you can only get the same deduction that a single person can get. And so then you start thinking about, well, if you have a married couple and really you're only giving them the same allowance as a single individual. So you're not encouraging married folks to both go get an education. So which one are you encouraging to get an education? It doesn't take a lot of imagination to think about whom when we're thinking about a code that structured in a way that's encouraging men to go out, to work and women to stay at home when they're married.
Bridget J. Crawford:And let's also add to this, the state tax systems as well. We've focused mostly in our conversation on federal law. That's a lot of the mainstay of law school classes, but look at state sales taxes, for example, and the fact that in over half the states, there's still a sales tax on menstrual products. Now that's gender neutral on its face. It doesn't say women pay a tax on these products, but there's a sales tax imposed on menstrual products in the majority of states. Whereas the majority of states do not tax things like Viagra, condoms. They don't tax tattoos in some jurisdictions, newspaper, ink, jet fuel, or cowboy boots in some jurisdictions, but menstrual products are taxed. Now, of course, both men and women buy menstrual products either for themselves or for folks in their household. But these are products that are used for a function that is so closely associated with what has historically been called female biology, that I think there is a very, very strong case that that in and of itself is a form of gender discrimination. And that's an article I've written with my Pace colleague, Emily Waldman. So we have to look not just at the income tax and deductions and things like childcare, but these taxes we've paid our entire lives. And we don't necessarily notice them like what is called the tampon tax, these tax on menstrual products at the state level, again, not a federal issue, but what kind of message are we sending when we tax products that are so closely associated with so-called female biology and on any given purchase? It may not be very much, but it adds up over a lifetime. And in fact, several states have said they don't want to repeal the tax because it's an important source of revenue. Well, then you're balancing state budgets on the literal bodies of those who menstruate and that is wrong.
Carolina Vargas:Absolutely. Thank you for bringing that up, Bridget. And then my last question for you both is how can people start to look at the tax law with this viewpoint in mind?
Anthony C. Infanti:How people can start to look at the tax law with this viewpoint in mind is constantly questioning and actually starting to read some of the work that critical tax folks have done. I mean, Bridget and I both do this work, but we are not by any stretch of the imagination alone, nor have we been. And so looking at the work of others, I mean, cause tax law can be arcane. Sometimes this stuff will be kind of right on the surface of things like that dependent care deduction that was in the Moritz case where it will be right on the face of things that will happen occasionally. But a lot of times, you don't really understand what's going on until you dig a little deeper. And so that's where kind of getting the benefit of the expertise of folks who spend their time studying the tax laws and looking at the tax laws from this perspective can help you to see what's going on and how this is working. And just thinking about how you're interacting with the tax code yourself every day. I mean, cause that's the thing that people don't realize is things happen every day that are triggering taxes. You may not file your taxes till next year, but I know even myself, like I have a little file. It's like I'm constantly putting stuff in it, so that way I have all my records that I need for, when I fill out my tax return, come February, March, whenever it is. And so, things are happening all the time, so think about well what's happening. And I was just thinking about the other day, just to give you an example, so this summer I had an 11 year old, I talked to you before about how I have a daughter and have to worry about childcare. And so, my partner got laid off during the pandemic. And so last year he had some wages and stuff leftover, but this year he's been unemployed the whole year. And so thinking about, well, I sent my daughter to camp some over the summer, just basically childcare and think about, well can I qualify for the dependent care assistance credit for that? Because that was childcare for her while I'm still working, obviously and my partner is unemployed and looking and saying, well, the dependent care assistance credit, that is limited by earned income. It's like so if you don't have earned income, then you can't take it. So let's see, well, what qualifies as earned income, but what does it qualify as earned income is unemployment. So unemployment compensation. So you think about, especially with the pandemic going on, how many people have been unemployed and getting unemployment compensation? And that may be all the earned income that they have. And if you're out looking for a job, you need childcare too, right? Because I doubt you're going to be wanting to drag your child to all your job interviews and all the other stuff that you're doing. And thinking about how that works and the kind of implication that has, especially in the current atmosphere that we have. That's something that like I said, it doesn't take a lot of imagination. You just have to start thinking about, OK, well, how is this going to impact me? How does it work? And how is it going to affect a lot of other people that are in the same situation, especially how's it going to be affecting different groups that have traditionally been marginalized as site? How is it affecting women? How is it affecting racial minorities? How has it affect the LGBTQ community? How is it affecting people who are immigrants and just down the line, all these different groups, just starting to question and think, it's opening your eyes is kind of the most important thing.
Bridget J. Crawford:And so I think Tony really is ending where we began, which is a feminist perspective on the tax law is linked to every other issue. Scratch the surface, and you will find that tax justice is an integral part of whatever one's concern is, whether it's fair housing, workers' rights, education, prisoner's rights, environmental issues, disability rights, LGBTQ issues, international trade, elder law, poverty law, racial justice, family owned business, immigrants, scratch the surface and tax lurks not far below. There's a burgeoning community of folks who are interested in making these connections. And in the end, that's what feminism to me means, making the connection between all of these issues so that we can build the society that we want and deserve to live in and have a tax code that reflects our highest and best values.
Carolina Vargas:Absolutely. Well, this has been great. Thank you both so much for talking to me today.
Anthony C. Infanti:Thank you.
Bridget J. Crawford:Thank you.
David D. Stewart:Now coming attractions each week, we highlight new and interesting commentary in our magazines. Joining me now is Acquisitions and Engagement Editor in Chief Paige Jones. Paige, what will you have for us?
Paige Jones:Thanks Dave, in Tax Notes Federal three practitioners argue that unrealized appreciation from derivatives isn't 16th amendment income, and that therefore a tax on it must be ap portioned. Erwin J. K atz explains why he believes that the IRS should apply this substance-over-form doctrine to provide tax relief to victims of various types of shams. In Tax Notes State Lyn n Ga n dhi ex amines this Zelinsky case and how the increase in remote work because of the COVID-19 pandemic could affect the case's outcome. Nic holas Ku mp and Travis Jackson, look at how states have approached granting tax exemptions for non profit ho spitals. In Tax Notes International Ron Debraski examines the policy considerations for limits on the taxation of controlled foreign corporations in the Biden Administration's proposed changes to the GILTI and FTC rules. J. An thony Kauflin explores the Biden proposal. J. An thony Kau flin ex plores the Biden proposal to eliminate the deduction for FDII and replace it with more support for research and experimentation expenditures. In Featured Analysis, Rox anne Bl and examines the Sirius XM case in which the Texas Court of Appeals Third District ruled that Sirius's receipts should be attributed to Texas, but hopefully the state Supreme Court will set it right. And finally, on the Opinions page, Robert Goulder examines competing tax reform proposals from the Biden administration and congressional Democrats.
David D. Stewart:That's it for this week. You can follow me online@TaxStew, that's S-T-E-W. And be sure to follow@TaxNotes for all things tax. If you have any comments, questions, or suggestions for a future episode, you can email us at podcast@taxanalysts.org. And as always, if you like what we're doing here, please leave a rating or review wherever you download this podcast. We'll be back next week with another episode of Tax Notes Talk.