Larry Gibbs commented on the U.S. Court of Appeals for the DC Circuit ruling that affirmed the decision of the district court in Loving v. IRS. The DC appellate court struck down rules aimed at establishing standards for tax return preparers, agreeing they may be considered a regulatory overreach on the part of the Internal Revenue Service (IRS). Gibbs said "the holding, rationale, and language in the two Loving decisions ... represent a clear loss for the IRS with respect to its authority under Circular 230 as it's now written to regulate the conduct of unregulated commercial tax return preparers." He added that the two opinions are "likely to cause the IRS additional difficulty in administering the provisions of Circular 230 and attempting to regulate conduct of practitioners before the agency."