The American College of Tax Counsel filed an amicus brief on October 23 in the U.S. Court of Appeals for the Eleventh Circuit in Scott L. Shleifer and Elena Shleifer v. United States, No. 25-12719, supporting the plaintiffs-appellants. The case raises important questions about the proper scope and application of the substantial variance doctrine in federal tax refund litigation. Tax Department Chair and American College of Tax Counsel President Michael Desmond said, "The amicus brief provides essential perspective for the Court of Appeals on the importance of ensuring access to judicial review in tax disputes through proper framing of the substantial variance doctrine."