The Supreme Court this week heard its biggest tax case of this term and, based on how the oral argument went, the IRS could be headed for a significant loss.

On this episode of our weekly podcast, Talking Tax, host Jeffrey Leon talks to Bloomberg Tax reporter Aysha Bagchi, who is covering the case, CIC Services v. IRS. She says some of the justices made comments suggesting they were inclined to rule against the IRS and thereby limit its ability to avoid judicial review of a reporting requirement before a taxpayer has violated the requirement and been given a penalty. Some argue that could make it a lot harder for the IRS to go after tax shelters, while others say it would help ensure that such requirements are legally valid.