Lisandra Ortiz discussed the limited use of Skidmore deference in tax cases at the D.C. Bar's 2026 Annual Tax Conference. Ortiz's remarks followed a presentation by the Department of Justice (DOJ) on data showing the government has won about 60 percent of post-Loper Bright challenges – similar to pre-ruling trends – despite the Supreme Court's 2024 landmark decision in Loper Bright Enterprises v. Raimondo curbing agency deference. Ortiz noted: "We have a small pool of decided tax cases that deal with validating agency regulations. Within that, there are even fewer cases that actually have any substantive analysis of Skidmore."