I’m on the road again! It’s tax conference season, and my first stop in June was San Antonio, Texas, for The Tax Retreat. It’s been a terrific experience meeting up with my fellow tax professionals. I even ran into Charles Barkley (okay, I suspect he was here for the NBA Finals and not to talk tax, but still).

Of course, there was plenty of tax, too. One of the highlights of the week was hearing National Taxpayer Advocate Erin Collins sit down with Terry Lemons for a conversation that felt refreshingly candid. Rather than sticking to Washington talking points, Collins focused on what taxpayers and practitioners see when the system does not work the way it should: delayed refunds, confusing notices, collection problems, and taxpayers who cannot get answers through ordinary IRS channels.

Collins described the Taxpayer Advocate Service (TAS) as both a lifeline for taxpayers in those situations and a watchdog for the broader problems. That work is getting harder. She said TAS case inventories are climbing while the organization has lost roughly a quarter of its case advocates, leaving employees with heavy caseloads and taxpayers waiting for help on issues that are often urgent. Still, she pointed to signs of progress, including clearer math-error notices, movement toward automatic first-time penalty abatement, and bipartisan interest in taxpayer-service reform.

Fairness was a thread throughout Collins’ conversation: whether taxpayers can understand IRS notices, get timely help, and trust that the system gives them a meaningful chance to be heard. That same question—what fairness requires when the government is collecting taxes—is also front and center at the Supreme Court.

In Pung v. Isabella County, the justices are considering how much equity homeowners can lose when the government seizes property to collect a tax debt and sells it at auction. The case follows Tyler v. Hennepin County, where the Court unanimously held that governments may not keep more than they are owed after a tax sale, but Pung asks the next question: whether compensation should be based on the auction price or the home’s fair market value.

In Pung, the tax debt at issue was a little over $2,200. But, after a foreclosure, the home, which was appraised at nearly $200,000, sold at auction for about half that value. The county returned what was left after the auction, and the estate argued that they should have received more, since they lost their equity in the home (for a tax debt they also claim was never owed in the first place). Be on the lookout for a possible SCOTUS opinion later this month.

Fairness was also an issue in a pair of recent Employee Retention Credit (ERC) cases, though the taxpayers landed in very different places. In Tri-State Memorial Hospital, a federal district court in Washington allowed a hospital’s refund suit to move forward, rejecting the government’s attempt to narrow what counts as a partial suspension and whether that suspension was “due to” government orders. That same day, however, the Court of Federal Claims sided with the government in Northeast Health Services, applying a more restrictive view of causation and ending that taxpayer’s case.

The split matters because ERC claims often turn on the same basic question: How much room did Congress intend to give employers that kept workers on payroll while government orders disrupted normal operations? The IRS has taken a narrow view in many of these cases, but as the litigation develops, courts are beginning to test where the statutory line really is—and whether agency guidance can be used to turn safe harbors into hard-and-fast eligibility requirements.

Another agency move is also in the news. A new USCIS memorandum focused on immigration policy may have tax consequences, too. By steering some green card applicants toward consular processing abroad rather than Adjustment of Status in the U.S., the policy could delay lawful permanent residency for certain foreign nationals—and, in some cases, delay their becoming U.S. tax residents.

What does that look like? Immigration status and tax residency are not the same thing. A foreign national may become a U.S. tax resident by getting a green card or by spending enough days in the country under the substantial presence test, and once that happens, worldwide income and extensive foreign-asset reporting rules can apply. For some applicants, a delay in green card timing may create more room for pre-immigration tax planning, while for others, especially those already meeting the substantial presence test, the tax result may not change at all.