Robert Kovacev will speak at the Tax Executives Institute (TEI) - San José State University (SJSU) High Tech Tax Institute on November 4, 2025. Kovacev will present, as a part of a panel, "Controversy and Guidance in a Constrained and Restricted Environment." A significant drop in IRS examiners and related functions means fewer, shorter, or modified examinations, and significant restrictions on the ability of Treasury and the IRS to issue guidance brings new compliance challenges. This panel will discuss what to expect, how to manage risks, the increased relevance of state agency actions, and strategies for dealing with uncertainty.