Audits, Litigation, and Remote Workers with Masha Yevzelman

Hosts & Guests

Masha Yevzelman, Litigator at Fredrikson & Byron, P.A.

Meredith Smith, State and Local Tax Senior Manager

Judy Vordran, Leader, Educator, Advocate, J.D., CPA

 

Summary

In this episode of SALTovation, Meredith Smith and Judy Vorndran continue their conversation with Masha Yevzelman, Litigator at Fredrikson & Byron, P.A. They discuss the challenges of litigating tax cases and the lack of consistency in state tax laws. They highlight the need for factor presence thresholds and small business exemptions. Masha shares examples of significant cases, including a property tax exemption dispute between government entities and a residency case involving conflicting state interpretations. Masha, Judy, and Meredith emphasize the importance of understanding the impact of tax decisions on individuals and businesses.

Topics Discussed in this Episode:

  • Factor presence threshold standards for income tax
  • Challenges faced by large businesses in tax litigation
  • Impact of state tax rates on controversy
  • Tax consequences of residency decisions
  • Shift in remote work and its impact on tax considerations

Quotables:

    • “When you look at a visual of which states have factor presence for income tax purposes, it’s pretty clear that it’s a very small number of states. But what’s interesting about the MTC position is the MTC said if you’re going to adopt this website position state, you should have factor presence.” -Masha Yevzelman [01:27]

     

    • “That’s why the litigation is a challenge. You’ve got to have the big taxpayers doing it, not the little guys unless there’s a giant class action that takes time, effort and bandwidth to support. So you just don’t see the advocacy unless you’re a large multinational business.” -Judy Vorndran [03:01]

     

    • “Some cases really aren’t suitable for settlement. Like I said, it’s kind of an all or nothing proposition. It’s an ongoing issue. Clients need certainty, too. And so even like settling a few years in an unprincipled way doesn’t fix it because then what about all the later years where the facts are the same and the law is the same and what are we going to do then?” -Masha Yevzelman [04:50]

     

    • “We’re seeing more aggressive state positions. If you know that that’s the position of the Department of Revenue and the auditor is applying it and the appeals officer is going to apply it, then really the only way to challenge it is through litigation.” -Masha Yevzelman [06:01]

     

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Transcript

[00:00:00] Meredith Smith: Welcome to SALTovation. The SALTovation Show is a podcast series featuring the leading voices in SALT, where we talk about the issues and strategies to help you make sense of state and local tax. Yeah. And as you were, as you were talking about kind of like litigating the 86272, I was like, all right, are we going to have, you know, a modernized Wrigley, right?

[00:00:22] Meredith Smith: Where it's like you went into the convenience store to swap out your gum. Here's the stuff that you could do. Here's the stuff that you could do and have that exact check versus,

[00:00:30] Meredith Smith: you know, what you can and can't do and how that's going to translate to that modernized And if, you know, states, it always kind of blows my mind when you look at kind of the factor of presence threshold standards from, you know, wayfarers in all 50 states, 46 states, whatever.

[00:00:52] Meredith Smith: And still for income tax purposes, there are only, You know, what, 15 ish from like a corporate income tax side that [00:01:00] have that factor presence threshold that more people haven't, people, more states haven't put that in and so where, you know, and maybe they're not incentivized to anymore if you can't claim 86 272 at

[00:01:13] Masha Yevzelman: all, like how that would kind

[00:01:16] Meredith Smith: of transfer across or if, you know, there is going to kind of be that small business exemption ish.

[00:01:23] Meredith Smith: Right. From, you know, an income tax perspective.

[00:01:26] Masha Yevzelman: Yeah, the map is actually pretty shocking when you look at a visual of, like, which states have, um, factor presence for income tax purposes. It's, I mean, it's pretty clear that it's a very small number of states. Um, but what's interesting about the MTC position is the MTC said if you're going to adopt this website position state, you should have factor presence.

[00:01:48] Masha Yevzelman: And, um, you know, Minnesota with the draft revenue notice, we don't have factor presence. We don't have any threshold for economic nexus on the income tax side, but you know, we're picking the MTC positions that [00:02:00] we like, I guess, and kind of not following through on the, on the secondary recommendation, which is if you're going to do this, you should have factor presence because you need a small seller exception.

[00:02:11] Masha Yevzelman: And secondly, that if you are going to adopt these standards, you should do it through rulemaking. I haven't done that either to draft revenue notice. So interesting.

[00:02:22] Meredith Smith: Yeah. Well, California, even though, you know, has, there was one of the first or the first top three call it. We still even got a pushback for one of our clients.

[00:02:32] Meredith Smith: It's like, okay, we aren't physically there. We don't even visit. We have some customers. We are well, well below the adjusted for inflation, sales threshold and California is like, yeah, but you're an income here. So, file a return. Wow. And it's like, we're not going to litigate it, we're not going to spend any more time because it's the minimum tax, they owe the 800 bucks, and they're going to do it.

[00:02:54] Meredith Smith: Spend 15, 000 to argue this position and it's not

[00:02:59] Masha Yevzelman: and maybe worth

[00:02:59] Judy Vordran: it. [00:03:00] Take three years, right? Yeah That's why the litigation is a challenge You've got to have the big taxpayers doing it not the little guys unless there's a giant class action that takes time effort and and And bandwidth to support so you just don't see the advocacy unless you're a large multinational business So there is this thing where the biggest businesses of our America of America are bearing the burden of all the small businesses are non compliant.

[00:03:23] Judy Vordran: And it's just sort of this push pull of like, what is efficient? It's really very kind of sad, but I don't see that changing with

[00:03:32] Masha Yevzelman: states, right? And I also think it's going to be in the high, high state tax rate. Right? Like those are the states where you're going to see the controversy on this topic instead of like, or

[00:03:42] Judy Vordran: a lot of population and we got 30 minutes.

[00:03:44] Judy Vordran: I look at our map of America, right? Like our states are very similar in size. So, you know, you got New York, Texas, Illinois, California, Florida, 30 million humans live there. There's a lot of tax needed to support the infrastructure of those [00:04:00] states. So, you know, They have the wherewithal to justify hiring more bodies, to do more enforcement, to be, but you just don't see that always in the smaller states.

[00:04:09] Judy Vordran: So, I mean, you think South Dakota mattered to Wayfair. Give me a break. There's 800, 000 people there. They're going to turn on the nexus and collect the tax. They didn't need to take that case to the Supreme Court, but they did it kind of as a courtesy, right? I think. Uh, because that's a lot of cost to argue a Supreme Court case and not know what you're doing when you could easily collect the tax

[00:04:29] Masha Yevzelman: from your customers at the front door.

[00:04:30] Masha Yevzelman: Right, but it makes a difference all across the country, too. So, you know. Yeah. And it did. Do you

[00:04:35] Meredith Smith: see in, uh, Any similarities other than, you know, getting mad at whatever jurisdiction you're going to litigate, and type of business that is able to take a tax issue all the way through litigation?

[00:04:48] Masha Yevzelman: Yeah, I mean, there's some clients want to do it on principle, right?

[00:04:52] Masha Yevzelman: And so those are the ones that are like, this is just wrong. And we're going to litigate it. Some cases really, [00:05:00] Aren't suitable for settlement. Like I said, you know, it's kind of an all or nothing proposition. It's an ongoing issue. They just, clients need certainty too. And so even like settling a few years in an unprincipled way, it doesn't fix it.

[00:05:13] Masha Yevzelman: Because then what about all the later years where the facts are the same and the law is the same? And what are we going to do that? And the other reason we see some litigation is there's just a long lag time in administrative appeals. So you get an auditor that's, you know, rogue or totally wrong. And at that point, you have a choice.

[00:05:32] Masha Yevzelman: Do we sit in an administrative appeal for three, four years while we wait for a decision? And again, maybe you get some certainty and maybe you don't, or do you just push it to litigation to get an answer quicker because we really can't afford to, or don't want to wait, don't want this pending over our heads.

[00:05:50] Masha Yevzelman: And lots of settlements can be achieved once litigation is filed. So it's just. Sometimes a quicker route to get to an answer, um, and to get it in front of [00:06:00] someone than the auditor, but I do think too, we're seeing just, like you said, more aggressive state positions, you know, and if you know that that's the position of the department of revenue and the auditors applying in the appeals officer is going to apply it, then really the only way to challenge it is through litigation.

[00:06:19] Judy Vordran: Well, we recently, with our home rural cities, we have this pay to play law. So if you want to litigate us, go to the district court to litigate a case at our city level. You got to pay the tax as if you owed it. I mean, that was crazy that we have that rule. So our, this coalition I've been involved in for the last six plus years, we got that law eviscerated.

[00:06:35] Judy Vordran: We don't have that. So you could go immediately to district court or you can go to conferee, which means you're going to lose. So stretch it out forever because they're going to keep having the government deciding against you. So that's been a huge benefit. But we as a state didn't have that opportunity until just recently.

[00:06:49] Judy Vordran: So, and you know, litigation is very different across, but I agree with you. If you threaten litigation, you do get settlement discussions quicker. And then it really just comes down to the money, but also today and tomorrow. So you have [00:07:00] to consider both. Because it's that consequence, Hughes, if you capitulate here, you got to keep that standard tomorrow.

[00:07:06] Judy Vordran: It's, that's the thing that's disheartening sometimes. Judy,

[00:07:08] Meredith Smith: how many times have we seen that, you know, you come to kind of an agreement under audit, but audits have no precedent, it's no rule, and it'll change from auditor to auditor, from day to day, you know, they could interpret something, exact same facts, exact same company, exact same, you know, invoice from a company, but it's whatever happened on your prior audit has no bearing on what's going to happen on this

[00:07:30] Masha Yevzelman: one.

[00:07:30] Masha Yevzelman: Yep. We have a case in litigation just like that. Prior audit had favorable result. Issue was considered and evaluated. Subsequent audit, opposite position, tax assessment. And like, what do you do? Right? So I think that's exactly right. So then

[00:07:47] Meredith Smith: kind of, is there any, you know, we've as a non lawyer, I just find kind of the, the process of taking something to court and arguing.

[00:07:56] Meredith Smith: fascinating. And I think a lot of, you know, accountants who aren't [00:08:00] lawyers, this is kind of another side that, you know, we haven't gotten to like touch, taste, feel and whatnot. Is there a case that you were a part of or, you know, that really kind of made an impact on you?

[00:08:13] Masha Yevzelman: Yeah. Um, there are a couple that I could talk about.

[00:08:18] Masha Yevzelman: Um, so one of them is over and it was actually a property tax exemption case. And so in that case, we had a government owned hospital fighting with the county over property tax dollars. And so we had a, um, it's called a hospital district, which is, um, A government entity, right? It's just like a bunch of cities that come together to form a hospital district to operate a hospital in a rural area and the county Decided that these clinic properties that were owned and operated by the hospital should be subject to property tax So the hospital district to pay that property [00:09:00] tax assessment levied its own property taxes And so it was like literally a situation of like taking property tax dollars from one government entity and giving it to another and that's what Like this whole fight was about and it went up to the minnesota supreme court and sure enough the clinics were exempt and the hospital district Um prevailed on that but the fact that this had to get litigated Just like to resolve this dispute between two government entities just like really shows.

[00:09:30] Masha Yevzelman: I think how much You inefficiency there is. Like sometimes I think everyone just needs to step back and be like, what are we actually talking about here? So that was a case that I thought was really significant and meaningful. And it was for a good cause, right? Like, because when the hospital saves on property tax and invests in health care like it buys more MRI machines, um, instead of just handing the money over to another government entity.

[00:09:58] Masha Yevzelman: So we, especially when the, [00:10:00] the

[00:10:00] Meredith Smith: primary purpose was to provide care for a group of, you know, constituents that don't have care because they're not, you know, in direct. You know, they're close to a city

[00:10:09] Masha Yevzelman: or exactly, or those are the whole point. The whole reason the district exists is to provide access to health care to rural Minnesotans who don't otherwise have that access.

[00:10:18] Masha Yevzelman: And so it was just kind of a crazy situation. So that's one example. I have more if you're interested, but yeah, what's, what's one more. Okay. So the other, I just personally love those stories. Yeah. So, um, another one is a residency case that I litigated. So in that case, Mark moved to Florida and his wife and adult daughter who had disabilities remained Minnesota residents.

[00:10:45] Masha Yevzelman: And the state's argument in assessing tax and saying Mark was still a Minnesota resident was that spouses have joint intent. Like you can only have one intent as a spouse couple and [00:11:00] also that if Mark really had moved to Florida, he would have had to abandon his wife and daughter and like all of these arguments in the face of the fact that like they went to Florida all the time to be with him and he was visiting them in Minnesota all the time.

[00:11:14] Masha Yevzelman: But the reality was is that. That the adult daughter needed to be a Minnesota resident because her healthcare providers were here because her only sort of social circle was here. So she had to remain that kind of home base in Minnesota for medical reasons. And the fact that this case had to get litigated through trial, I think was also really disappointing because, you know, I mean, the court rejects the idea that you have to have one joint intent, each spouse can have their own intent as to where they want to live and to like for the state to come in with.

[00:11:46] Masha Yevzelman: Like presumptions about like human nature kind of I think and the Just the impact on that family and the assumptions that they made that you know Really weren't reflected in the facts and to have to go through a trial on something like [00:12:00] that. I think was really Disheartening and he's

[00:12:02] Judy Vordran: only owning he only has his by default his residence is why minnesota gets to tax it He may not even be making his

[00:12:08] income.

[00:12:09] Masha Yevzelman: He was retired. So it was all just you know Interest income, basically dividends, right? So it was that's

[00:12:17] Judy Vordran: brutal. That's because it takes away free will you like I have enough wealth or whatever I could have dual residency. I could live in multiple places. You see a lot of like I think about Tina Turner, who just passed away living in Switzerland.

[00:12:30] Judy Vordran: I'm sure there was a reason for that. Um, she obviously had a 70 million place there, but she probably was paying so much U. S. federal income tax on her worldwide earnings. She's like, I got to separate from this nation that I love, but I'm not gonna. Pay all this tax just because, yeah. So you wonder about that, that people have to make decisions about where they live because of this

[00:12:51] Masha Yevzelman: crazy tax structure.

[00:12:52] Masha Yevzelman: And I mean, I think he really wanted to live in Florida. It was what he wanted to do in retirement. He lived in this community, um, that was important to [00:13:00] him. It's where his social friends were. Social Circle was and they really, um, spent a lot of time together as a family, but just home based in different locations.

[00:13:11] Masha Yevzelman: And that was not something that the state really could understand until we got all the way through trial. There's

[00:13:16] Judy Vordran: so many Minnesotans and Wisconsinans. Right. Cause it's cold there where you live. They want to be

[00:13:23] Masha Yevzelman: like dipping their toes into Florida. So they'll go for like four weeks or six weeks. And then it becomes three months.

[00:13:29] Masha Yevzelman: And then they're like, why am I just not here most of the time? So it's a, it's also very, very active area in Minnesota right now with people moving to Florida and the state auditing those moves. And a lot

[00:13:42] Judy Vordran: of New York hands live in Florida.

[00:13:44] Masha Yevzelman: That's got the Naples side and New York has like the Miami side.

[00:13:50] Meredith Smith: Different cultures of like where they're relocating from. Yeah. Naples

[00:13:53] Masha Yevzelman: is just part of Minnesota.

[00:13:54] Judy Vordran: But really, you kind of are born somewhere. You stay or not. I was just visiting family. My husband is one of [00:14:00] six. Just visiting family in Atlanta. Out of all his six siblings, only three live out of state. And it was only two.

[00:14:06] Judy Vordran: Him and his oldest brother. And his oldest brother just lived like three hours north. His youngest brother relocated from Indiana to Georgia. I mean, that was a huge life shift for them. So, but, you know, job related and it made sense, but, you know, just, you don't leave your roots usually because you have your community there.

[00:14:24] Judy Vordran: So to up and relocate is kind of a big deal. So you better, it's can't just be tax oriented, it's lifestyle

[00:14:31] Meredith Smith: oriented. Well,

[00:14:31] Masha Yevzelman: personally, like I'm prepared

[00:14:34] Meredith Smith: for. for some pushback on my Minnesota tax return from Colorado because my husband was going to move there. So we had, you know, dual, I was staying here with our kids for a personal reason, right?

[00:14:47] Meredith Smith: He was establishing work in Minnesota, but then that didn't work out, right? So he moved back here as soon as he could. And even like the beginning parts of his kind of Minnesota job were done [00:15:00] remotely from here. But then, you know, we're also, he was also collecting Minnesota unemployment, not living in Minnesota, but paid into the system, the job paid into the system.

[00:15:09] Meredith Smith: So I'm just waiting for Minnesota to not like my tax

[00:15:13] Masha Yevzelman: return. Oh, totally. Yeah. That sounds like a huge. And I'm not even like. Yeah. Totally.

[00:15:17] Meredith Smith: I don't, he didn't make that much money to make it worth their fight, but there's a big difference between a Minnesota 9. 7 percent rate and my Colorado four and a half.

[00:15:28] Masha Yevzelman: Totally.

[00:15:28] Judy Vordran: It's not funny. Cause we obviously, as you know, have another teammate in Minnesota who we hired a hundred years ago at a former firm I worked at and we had an office in Minnesota. So it was logical to have him. Um, but now, you know, we aren't in Minnesota as a HQ, but now with like, whatever, he's a good person.

[00:15:46] Judy Vordran: Let's hire you. I don't care where you live. Yeah, so that's been a huge shift in even my career. You know, I mean, you're in your office. I'm in my house. I don't even go out to my office anymore because no one is there.

[00:15:59] Masha Yevzelman: These are a little [00:16:00] slim around here. But yeah, so we just moved offices. So that's our big update.

[00:16:04] Masha Yevzelman: So Monday was our first day in this new space. So we're still kind of trying to figure out where, but yeah, so I was in on Monday and then today, but home Tuesday, Wednesday, Thursday.

[00:16:15] Judy Vordran: And then downtown similar. Okay. Yeah. Cause that's another thing like we're struggling. We're off a lease next year and we're like, what are we going to do?

[00:16:23] Judy Vordran: Hardly anyone goes in the office anymore. And now we're in 10 States. We have employees in 10 States because we have opened the door to the people, not to the tax. We want to have good people. And if they're living in whatever, Fine, we'll figure out the tax. We're tax preparers, we can deal with it. But we, you know, it's been kind of a funny, um, segue in even my career.

[00:16:42] Judy Vordran: I remember years ago, my husband and I got married. He wanted to live in Telluride, like a remote mountain community. I'm like, where are we going to work? I'm not going to be a waitress. I mean, fine, but that's not what I want to do. I don't want to rent a hotel. What am I going to do for a living? Now I can have done it.

[00:16:56] Judy Vordran: Of course, I couldn't afford to live in Telluride. It's very expensive. But regardless, that's been [00:17:00] a huge shift into our mountain communities in Colorado alone. People are like, I want to live in Steamboat. I want to live in Aspen. I want to live in Winter Park. I don't need to live in New York in a little tiny apartment that I can't leave.

[00:17:11] Judy Vordran: So there's been a huge shift in America about where they want to live for their day after work hours. For sure. Yeah.

[00:17:18] Meredith Smith: So as we kind of wrap up, you know, we talked about maybe 86272 could be the next hot button. Maybe some other residency, part year remote work. Is there anything, you know, as, you know, practitioners that we should be thinking about or have any parting words for, from our badass litigator

[00:17:43] Masha Yevzelman: friends?

[00:17:44] Masha Yevzelman: Yeah. I mean, I think we've already been seeing an uptick in litigation over sourcing, a preview of our little presentation. And

[00:17:53] Meredith Smith: I think [00:18:00] there's going to

[00:18:06] Masha Yevzelman: be more, right, like, so we've already seen some of like, is cost of performance really market based? Um, and what does market based mean and how do you even get a service and where does you do you get a service and who's the customer and there's just so many unanswered questions still.

[00:18:25] Masha Yevzelman: Um, there's been some litigation on it from certain states that I think have been active, but I think more and more states are going to be litigating the sourcing issues, um, just because there's a lot on that right now. I also think just. Pass through entity taxation is going to continue to percolate, because like with, you know, Ask Special Holdings and with Goldman Sachs and other cases like that, it's so complex.

[00:18:52] Masha Yevzelman: And if you follow the Multi State Tax Commission's projects, their pass through entity project is [00:19:00] insanely huge. And so like just reading their issue paper, I mean, it's very long and it's just full of questions. And there are all these questions in all, like from nexus to like, do you follow federal to like sourcing, like in the past or entity context, like apportionment, like which entities factors do you use and when to unitary.

[00:19:22] Masha Yevzelman: I mean, there's so many unanswered questions in the past through entity space still that I think. Some of that will continue to percolate up through litigation and then not to pick on the MTC. But I think their study of the digital products space in the sales tax world Is going to create some controversy at some point because if we're gonna well this whole

[00:19:42] Judy Vordran: customer's customer stuff too Like who the heck bought it?

[00:19:46] Judy Vordran: Like people don't track this stuff. People just take a credit card online and transact business.

[00:19:51] Masha Yevzelman: Yeah, it's a problem. But if digital products are going to be defined like that, anything that has a one and a zero, and then if states decide to tax anything that's got a [00:20:00] one and a zero, I mean, we're going to have some sales tax issues.

[00:20:02] Masha Yevzelman: So I think there's a lot, there's a lot of like really, really interesting. Um, and I think fairly controversial in the state and local tax world areas that are going to be the subject of controversy coming

[00:20:14] Judy Vordran: up. And I think, um, I think about Uber or, you know, just any of these companies that are out there in the world of like non traditional business, even Amazon, right?

[00:20:25] Judy Vordran: Yeah, the gig thing. I mean, like everybody's just getting money. There's all this money moving in America that just could happen electronically and then somehow the service is reformed. Who, how do you source that? How do you tax it? Huge problem. And then a lot of business didn't grow up with a taxi mentality.

[00:20:43] Judy Vordran: So they didn't set themselves up procedurally to gather the information they need to tax it appropriately. So you don't have addresses, you don't have zip codes. Like they didn't even think about that when they took the money. Because they just ran the credit card and they needed a zip code, maybe. I don't even know

[00:20:58] Masha Yevzelman: that sometimes you need that.

[00:20:58] Masha Yevzelman: Sometimes they made [00:21:00] assumptions on how to do that. Like you said, who's the customer? Like, where are we even sourcing this thing? And that's, yeah, both sales tax and income tax side. The other area I think of active litigation that's going to be coming up is worker classification. So like on the gig economy space, right?

[00:21:12] Masha Yevzelman: Like the Ubers and all the others of the world that, you know, have, you know, independent contractors versus employees. That is like a huge area of controversy that we're seeing as well at the state level. So that is, I think that's also going to

[00:21:27] Judy Vordran: continue. Well, I think that comes from a procedural thing.

[00:21:30] Judy Vordran: So we have, as a society, put sales tax on the vendor, not on the consumer. We are putting income tax withholding on the employer. So who is the employer? So this all has to do with like, That's how we did it. It was, you know, this transaction, and now you're like, well, maybe not. And then, of course, small business doesn't want to have employees, really, because they don't pay all the withholding.

[00:21:52] Judy Vordran: They don't want to pay self employment tax. I mean, there's just all these tax related issues driving behavior. Instead of just doing what they need to do, [00:22:00] moving to another state, hiring a human, see if it works. Yeah, but tax is a rollout from that. Even if

[00:22:06] Meredith Smith: you were treated as an independent contractor, like the person who's just, you know, kind of got like a side hustle, they don't know what to do.

[00:22:14] Meredith Smith: My husband is, you know, kind of in between his W 2 jobs, kind of did some consulting stuff and he's like, what the hell am I supposed to do? And part of me as like, I

[00:22:24] Masha Yevzelman: live in

[00:22:25] Meredith Smith: this space, not maybe in that area of expertise, but I was like, it doesn't really tell you what to do. So like the average human who just wants to do things correctly or has a great idea doesn't know how to do it, which is kind of, Maybe one of the arguments that says, all right, Uber, you have to make them employees and you have to do all of these things,

[00:22:43] Judy Vordran: right?

[00:22:44] Judy Vordran: Yeah. Because we gotta put the onus on the, the larger company that has a capacity to handle the masses instead of the individual. And that's why the Wayfair case happened 'cause nobody was self-reporting use facts Well and the market and marketplace. Yeah. I remember I bought something. And my son, [00:23:00] when he was in New Orleans, and I never used Amazon until I started collecting tax, just so you know, because I don't want to be a hypocrite.

[00:23:06] Judy Vordran: Um, and he goes, Mom, if I get it on Amazon, I don't have to pay tax. I'm like, yes, you do, honey. You just don't get audited. He goes, Oh, I didn't know that. And I thought, isn't that funny? And he's much younger than me. Of course, he doesn't know that. So what are the younger generation think? And then all these people come up with these wonderful ideas.

[00:23:22] Judy Vordran: And Hey, we need this thing, but then they don't think to build the tax consequence into their automation solution. So it's a problem because you're backing into it sometimes with these very large now multi state entities that have been Expedia is a great example, Travelocity, but you didn't think about that.

[00:23:39] Judy Vordran: They just thought they were conned to do it like a commission agent. to, like, set up lodging when you got a couple extra hotel rooms. But are you really not selling the lodging to me? So shouldn't you be collecting it? Huge issue. Yeah.

[00:23:53] Meredith Smith: Well, Masha, thank you so much for, you know, your time today. And, you know, the relationship that [00:24:00] you have built out with, you know, some of our team members and I really look forward to presenting with you in a few weeks.

[00:24:06] Meredith Smith: And so just thank you so much for being here and joining us today.

[00:24:09] Judy Vordran: And taking such a leadership position, it's just exciting for me to see you up there and heading the women's initiatives and all the things you've been doing. Thank you for that. That's, that's wonderful to see this in my 28, 29 year career.

[00:24:24] Judy Vordran: I love seeing this very young generation coming in and taking a leadership role to set things forward. It's fantastic to

[00:24:31] Masha Yevzelman: see. Thank you. It's a lot of fun. It's, um, yeah, I love doing the women's organizations and groups and kind of having these relationships with you and with others. So thank you. Thanks for having me.

[00:24:42] Masha Yevzelman: This was a lot of fun. Yeah,

[00:24:43] Meredith Smith: well, this was SALTovation until next time. This podcast is for educational purposes only and is not intended nor should it be relied upon as legal tax. Accounting or investment advice should consult with a competent professional to discuss specifics of your [00:25:00] situation and the applicability of the information presented.