Dave: Hello, Brandon.
Brandon: Hey, Dave.
Dave: How are you today?
Brandon: I'm good. How are you?
Dave: I'm doing fine, thank you. Well, thank you for joining me on the IC-DISC show.
Brandon: Wonderful to be here.
Dave: Yeah, so my guest today is Brandon Frenza, with the law firm of Cantrell & Cantrell in Houston, Texas. And I guess to get started, why don't you tell me a bit about your background and where you grew up, where you went to undergrad, and law school, and how you ended up in the tax law world?
Brandon: Okay, well, I'm a bit of a traveler, and growing up my parents were in the military. So we've lived all over the country and overseas. But I typically call Reno, Nevada my home. It's where I went to school. And, my undergrad is in, strangely enough, digital media, which is sort of a computer science and graphics related background. Not really much to do with tax at all.
It's sort of how things go in school. But at some point, my wife and I, when we focused in on law school, we ended up here in Houston for law school. So I went to the South Texas College of Law. And shortly after that-
Dave: Well, hold on, hold on. Wait, hold on, I need to find out when you fell in love with tax. So was that at law school or after law school?
Brandon: Actually, yeah. So when you go to law school, you have these sort of dreams of being the next Perry Mason, or maybe that dates a little bit... I'm not sure if you're-
Dave: I'm familiar with Perry Mason.
Brandon: And South Texas, particularly is very good for trial advocacy. But I found out quickly in law school that I was more interested in the transactional side of law than litigation. And I took my first tax course in a summer class. So that's kind of an accelerated timeline. And it was probably the most feared class. All the students were just dreading it. And the particular instructor that I have is ruthless and focused on really destroying the students. He's very good at it. He's a former LLM tax professor from Florida State University. And he just loves to terrorize the students.
And for the first time in my life, that summer, I actually got strep throat and was very sick. So my first experience with tax was not one that you fall in love with. But somehow, I recognized early on that there's just such a connection with tax to just about everything that we do in this world, especially transactional. And I knew I wanted to get into the business side, and I thought that would be an excellent start for me to better understand the business side of the legal world.
That led me into more tax courses. South Texas is unique that we actually offer quite a lot of tax courses there. And there's a couple of professors that have experienced teaching at the LLM level, which is a masters in tax. And so I took as many of those courses as I could. Just soaked them up. And that led to an internship or an externship with the with a local chief Counsel's Office at the IRS here. And I did that while in school. And really just sort of developed an interest over time, sort of grew a taste for it.
Dave: Okay, so it wasn't love at first sight, but you just kind of warmed up to it overtime?
Brandon: No, no. If you had told me, years before going to law school, that one, I'd go to law school, and two I'd be in tax, there's no way I would have believed it. But now it's the right kind of fit. It's perfect for me. I enjoy it immensely. I find it to be very awarding and challenging at the same time.
Dave: That's great. Well, I'd like to hear a bit more about your IRS experience. What comes to mind that might have been maybe one of the best parts of being there? Or one of the most enjoyable aspects?
Brandon: Well, before I even intended to go over to the IRS, there's kind of this, "They're the enemy," mentality. And so going over to the IRS, I wasn't really sure what I would experience. But I found that, especially here at our local office, the chief counsel's office, that there's a really great team of attorneys there. And I learned from some very competent attorneys, that that their focus is on really trying to come to the best result.
My experience with the Tax Court over there was quite an eye opener. As I mentioned, I didn't really have a desire to be in the traditional litigation field. I wanted to be more transactional. When you're involved in tax, a lot of tax is transactional, but you can't really get away from controversy-related work. And the Tax Court situation is very different from your traditional trial court situation. It's nothing like it.
And because tax is so very technical, the judges that are appointed to the Tax Court, they have a very special understanding, not only of the code and the procedures, but of the taxpayer, and the taxpayer's inability to really understand all the rules. And so that was something that I learned very quickly while being at the IRS, that there's a lot of leeway given to try to help out the taxpayer get through these very complicated situations.
Dave: Wow, that's really interesting. I think most people's just assumption would be that it is a much more adversarial situation where they're trying to kind of find gotchas to trap the taxpayer. But that was not your experience.
Brandon: Well, there certainly may be. And I think now that I'm on the other side of the line, I see that, especially in the initial audit stages, there is a lot of that gotcha kind of mentality. And once you have made it to the level of going to Tax Court to defend your case, now you're dealing with the IRS. And it's not that they're not willing to aggressively pursue their position, but you're dealing with individuals who have a greater command of the tax code itself, and of the procedures and are really just trying to come to a result that is supposed to be the best results.
So I think that it is shocking to a lot of taxpayers. And I've seen many times when the taxpayer will show up in the Tax Court, and they're scared out of their mind. They look like they're afraid that they're going to be thrown in jail over a tax issue, only to find out that they can actually resolve it, in many cases, right there. Most tax cases don't actually go to the full extent of being tried. Most of them are settled, because there usually is a resolution.
Dave: Okay. Well, are there some examples of things that you learned during your externship that you find yourself using today?
Brandon: That's a good question. Tax issues are so encompassing and just complicated for not only the general individual or business, but even for tax professionals and lawyers. And I think one of the things that I've learned most was that you have to really be very careful when you go through a tax situation.
I also learned and I find this a lot in my practice now, that you cannot ignore a notice that comes from the IRS, when it comes to the tax issue. That you just can't ignore them, because that's really your opportunity to correct or defend a situation. You don't want to find out sometime later that you could have fixed it, and now things are worse and there's very little you can do about it.
Dave: Okay. So that sounds like a good general tax advice, really, for anybody, which is, when you receive a notice from the IRS, to take action promptly. Either responding directly oneself or retaining outside counsel such as your firm.
Brandon: Absolutely. Absolutely. And the other is, when the issues become very complicated... Even before I mentioned that, what I see a lot, both at the IRS, and now, when people get into trouble is, they get into some sort of a business transaction, and then they ask the tax question later. And I know I'm a little biased towards tax, because that's industry that I'm in, but I do a lot of business related work. And it is always better to ask the tax question first, and then get into the business transaction or into the whatever direction you're going. Because it's better to plan for the tax issue upfront than to try to deal with it later.
Dave: More wise advice. So it seems like our first two lessons for the day are, one, never ignore a notice and B, make sure that the tax consequences of a potential transaction and are really at the forefront.
Brandon: Yeah. Yeah.
Dave: Okay. Well, any other thoughts on the IRS that you want to share or any interesting stories or experiences from your time there?
Brandon: I think just in line with the idea that the IRS isn't necessarily always the bad guy, although I would tell you should never rely on what they say as the word, you should always challenge their position. They don't get it right all the time, most of the time in my case. But one positive note for the IRS is that, we had a case while I was working there with Chief Counsel where the taxpayer devolved a basis their cost on a house, and I noticed while digging through the reports from the revenue agent, that they hadn't even taken into consideration some of the transfer rules that applied to this particular transaction.
I pointed that out to the counsel involved at the time. And the end result we came up with was that there was no tax due to the taxpayer. But they had already made it through audit level and appeals level, and now they were at Tax Court. And we'd come up with a resolution that there wasn't actually a tax issue. And just the joy that the taxpayer had at the time, I think that's probably what really sealed for me that I wanted to be involved in tax, but more so on the other side, so that I could help my clients get to that resolution and not have to deal with that stress if we could help them avoid it. Because oftentimes, there is a simple solution and a way to resolve it.
Dave: Well, very interesting. Well, that then brings us to, so tell me about the firm that you joined. What made you want to join them? And just tell us a bit about the firm and some of the things they do.
Brandon: The firm is... We're a very unique, boutique law firm. It's Cantrell & Cantrell. And there's several unique features about the firm but I think the first one is that the managing and founder partners are husband and wife, Pat and Carol Cantrell. And what's unique is it's rare to find a husband and wife team in the legal field that work so well together, and Pat and Carol just complement each other and in every way, professionally and intellectually.
And they make the firm really a good place. It feels like a like working with family here. It's a wonderful environment. But I first met Carrol Cantrell while I was working at the IRS chief Counsel's Office. She and another associate of hers were handling an estate related case. And after we concluded our meeting, the attorney at the time was a senior attorney over there at the chief Counsel's Office, and very well respected. She told me aside that if I ever got the chance to work with Pat and Carol Cantrell, I should absolutely take it because they were highly respected as a community and very good at their job and very knowledgeable.
And it was a short time later when we were in tax court that I ran into Carol again. And I remembered that comment, and she offered me an opportunity to come over to the firm. So I couldn't pass it up. But that's how I met them initially.
Dave: Okay. Is my understanding correct that another unique thing about Pat and Carol is that not only are they both attorneys, but are they also both CPAs as well?
Brandon: They are. In fact Pat was a revenue officer with the Internal Revenue Service before that. They're both CPAs. Pat and Carol are both certified in tax. And believe Pat has 52 years in tax, and Carol almost about the same. And there's a third partner Derek Matta, he's our head of controversy. He's a former IRS Chief Counsel here out of Houston and out of the office in Louisiana, I believe. The combined experience is just immense.
Carol's even double board certified. She's got her state planning certifications as well. And their abilities are incredible. And they're both writing and publishing and often coordinating with other larger companies or larger firm who need someone with specialized tax ability. And Cantrell & Cantrell is unique because although we're a boutique firm, we are entirely tax focused. And we have seven tax focused attorneys just here at this firm. And we do large firm work but at a small firm atmosphere.
So it is a wonderful place to work and, and the work here is quite unique and exciting. Because we're covering just about everything that you can imagine in tax, from estate and business planning, as well as individual and corporate or partnership tax. We also covered administrative and controversy related issues. We'll even take it to Tax Court if necessary.
Dave: Okay. And I understand that the IC-DISC is part of your practice area, that you don't limit your practice IC-DISC. Is that correct?
Brandon: Correct. Yeah. We do cover a wide variety of topics. I, myself focus primarily on business and partnership related tax, and the DISC itself falls within that business category. Houston is just such a wonderful area because we have local and international business. Just it's a hub here. So there's a lot of export activity here which ties directly into the need for the IC-DISC.
Dave: Okay. So tell us a bit about IC-DISC; what's it stands for, how long has it been around, just some things for the listener who's maybe not an expert on IC-DISC.
Brandon: Yeah the IC-DISC is itself a complicated acronym. It's an interest charge, that's the IC, and domestic international sales Corporation, and that's where the term DISC comes from. So the DISC itself is something that was instituted by Congress in the '70s to address export activity.
It is called a domestic international sales Corporation because it's a US corporation that is involved in export products outside of the US. There's the international part. And as I'm sure we'll get into, there's a couple of ways that a DISC can be involved in exports, and the primary method involves the DISC receiving a commission for its involvement in the export of the export product.
Dave: Okay, well, why don't we just take a step back, so the DISC is like a S-corp, or C-Corp or LLC, what's the structure of the DISC?
Brandon: There are some very specific requirements for a DISC, moreso than just about any kind of entity that can be formed. Their Revenue Code covers this under sections 991 through 997. But in 992, specifically, the requirements for DISC are that it be a corporation. It has to be formed in the United States, and that actually has to be within the 50 states of the United States, it can't be a territory. So, it does have to be a corporation. It has to have at a minimum of $2500 worth of value in the company. So the way we handle that is issuing $2500 worth of shares at minimum so that its shareholders can meet that requirement.
Dave: Okay. And the... I'm sorry, I just kind of was thinking of something else. So please continue, you're giving a little background on the DISC?
Brandon: Yeah. There's several requirements for forming a DISC. It's got to have one class of stock, I think that's where I was going with the 2500. So it has to have one class of stock, and that there has to be at least $2500 in value of stock every day of the year for it to remain qualified as a DISC.
The DISC is a special tax election that has to be filed and received. And unlike some other types of entities, like an S corporation. With an S corporation, you can file the election and then you sort of act as though the elections already been approved. With a DISC, the election has to be approved. You can't just assume that it's been approved, although, if you're following the rules, I haven't run into a situation where they don't approve the DISC.
Dave: Okay.
Brandon: They are very specific that it has to be approved first. So if you file a form which is referred to as Form 4876-A with the IRS. And that has to be filed, specifically within 90 days of the beginning of the tax year for that entity if you want the election to take place. And then provided the IRS approves that, and I think even the backup there, the election itself has to be authorized, I guess is the word I'm thinking, by each of the shareholders of the company. And then any spouses of a shareholder that might be in a community property situation which we find here in Texas.
So if you have community property spouses, and they're not both necessarily shareholders of this DISC, the spouses of each shareholder and the shareholder have to sign the election in order for it to be valid. So that is very specific rules on electing for the DISC itself.
Dave: Okay. I know that the DISC is not your sole practice, but can you give us a sense of your the amount of DISCs you've been involved in? Is it just a handful? Is it hundreds? Is it dozens? Talk about the breadth of your experience?
Brandon: I'd say dozens. We've had quite a few. It seems that they come in waves. Every year, we have about a dozen or so formations. And then about a dozen or so, just very specific DISC-related research or question related tasks or issues come up so. And then even the occasional controversial related issue on DISCs, which is more rare, but...
Dave: Well, talk to us about some of your controversy experience. What's the typically the nature of those, or maybe give us an example of a particularly interesting one?
Brandon: Well, I don't know what the current number on how many DISCs are active today, but not too many years ago, it was just a little over 2000. So there's not a lot of DISCs when you compare them to, say a different type of entity structure. But even so there's not a lot of direct auditing on a DISC by the Internal Revenue Service.
And partly, and this is just my opinion, is because the requirements for DISC are so complicated that it does require somebody with specialized experience and understanding of the IRS level to even audit the task. What happens where an audit comes up and affects the DISC is that, oftentimes the shareholder or the related supplier or producer that is connected to the DISC because they're providing the export product is audited. And that oftentimes can be either another corporation or a pass through entity like an S Corporation, or some kind of an LLC. And they get audited, because that's more frequently the case or the individual themselves. And that leads the IRS to take a look at the DISC.
And in the cases that we've seen, often is that the agent doesn't understand the DISC, and they just see that there's a tax benefit happening here and they challenge it automatically. So sometimes unfortunately, it starts because the agents aren't really educated well enough on the DISC rules or its purpose.
Dave: So, do you find that you end up having to sometimes have to assist in that education process with a generalist agent?
Brandon: Absolutely. In fact, one case in particular, the agent did just that they were auditing the related supplier company. The supplier company had formed a DISC for its tax benefit, and the agent didn't understand the nature or the purpose. And when the agent looked into it, the agent found that there were specific requirements for export property and what qualified as an export property and they challenged that and said "No, your property doesn't qualify." Fortunately for the DISC, they had good advice before they even formed the DISC to help them prepare their... be prepared for what the qualifications are for export property. And their particular property was a scrap metal type of property or product that is. And the particular issue at hand was whether or not they were manufacturing export product and if scrap metal was export product.
So we walked the agent through, but the agent was so uncomfortable that with the complexity of the issues that they had to run this up the line to Washington DC and get a result back from DC. The end result was that they agreed with our information. And there was no taxable effect on the DISC, where the agent wanted to ignore the DISC.
But it's just an example that the IRS themselves don't know how to handle the DISC because they are not training their agents to do that.
Dave: It sounds like part of the reason is because there's so relatively few DISCs, that perhaps it's not the highest priority training.
Brandon: Yeah.
Dave: Just a relatively small number of them.
Brandon: Though, that's a very good way to highlight that. The IRS really does limit their area of focus to where they can spend the greatest amount of time. So because there are more individual taxpayers, they spend more time on individual audits, because there are more corporations, they spend more time on corporations.
But the area that DISC is not one where the IRS spends a lot of their time on it. So, it is important that when an audit comes up for a DISC, that you have someone who understands the DISC well enough to help educate the IRS and get them out of that situation, because there's often a lot of legitimate tax savings on the table there. And the IRS is happy to take those away if they think they don't apply.
Dave: Sure. Is my understanding correct that another potential area that the IRS may be confused on is it called the form over function or form over substance?
Brandon: Yeah, substance over form doctrine, correct.
Dave: Could you talk a bit more about that and how that applies to the DISC?
Brandon: Yeah, well, so particularly in this case of the manufacturing question, the agent was trying to say that although the form of the DISC was legitimate and follow the rules, that the substance, how they were carrying this out didn't meet the intended effect that the writers of the code desire. That the individual was taking advantage of the tax code, because they were getting a benefit that wasn't intended.
We had to help the IRS see that the actual use of the DISC met the very intention that the writers of the code had provided for. And in this particular case, there are some specific examples on what met the requirements. And we actually are... our export property was an exact replica of the example that was listed even in the code and the regulation.
Dave: So interesting.
Brandon: Yeah.
Dave: Because my understanding is that the IC-DISC is also sometimes referred to as a paper entity. And that it typically has no employees or activities and such that. Is that correct?
Brandon: Yeah, so there's two ways that a DISC can be used. It can be used actively or it can be used I guess, more passively, this idea of being a paper or a shelf company DISC, which is more common. A paper company is really something that is, and this is the substance over form document doctrine, it's formed, but is it really taking on the activities of a regular business.
And fortunately, in the case of a DISC, Congress provided specifically that a DISC does qualify for its activities even if it's not taking on the traditional business activities of having employees and actively having inventory and all of the other typical activities that you find in a business. It's a paper company because you form the DISC, and then its entire job is just to facilitate the tax benefit. And the rest of its activity really just happens on paper.
Dave: And so there's-
Brandon: Pension.
Dave: Yeah, thank you for that. And my understanding is that sometimes we'll kind of confuse the typical agent because this runs, I guess exactly opposite of the normal interpretation of that substance over form argument, right. That if it is a non-DISC business, doesn't really have much activity, that you-
Brandon: Right.
Dave: Could you talk a bit more about that?
Brandon: Yes. And usually a business has a required number of hours or activity that has to be put into it. And there are series of, like a checklist of activities that you could go through. Things that are action items that the business might be doing, that prove that it is in existence, that it's actively conducting business, that the business is legitimate, and so forth. And a DISC itself doesn't need to necessarily be involved in all of those things.
And that's one of the areas where an agent will say, "Well, we don't see that this company is actually performing any of its typical activities." And that's an area where we have to educate them here. According to the section in 992, it explains that the DISC doesn't necessarily have to be involved in regular business activity.
Dave: Okay. Okay. Again, thank you for that clarification. What are maybe some examples of two or three pitfalls that you see that sometimes shareholders will unintentionally fall into with a DISC? It sounds like one of them might be that they perhaps it not filed the election timely? Is that correct? And if so, what other situations Do you see that people get in trouble with a DISC?
Brandon: Yeah, certainly the first one is the elections filing, or actually, one of the first areas that I see is when, not the... the $2500 rule is that the shareholders have $2500 worth of value in the company when it begins. So this seems like a small amount, but oftentimes, entities are formed without any money being put into them. And then money comes as the entity needs it, or it takes out a loan or something. And debt doesn't qualify for this $2500 rule.
And when we're talking about the benefits of a company that would have such extensive gross receipts and revenue, $2500 is such a small amount to forget. So it's a little thing, but it's a requirement. And it's important that companies start out with it's $2500, then that it makes the election and all the shareholders sign that election and it gets filed within the first 90 days of the tax year. Those little rules are very easy to miss. It's easy to miss those deadlines.
And another deadline that is often overlooked, there is a requirement that if the DISC itself utilizes this position where it can be receiving commissions for its income, those commissions that it earns have to be paid to the DISC within 60 days at the end of the tax year. That's something that requires good accounting procedure on the part of the company, whoever's keeping track of accounting for the DISC. You need to have a good CPA or somebody that is keeping track of that. And they need to help remind you that those commissions that are earned have to be paid to that DISC within 60 days or the DISC could be disqualified.
And I think, maybe not a final, but another big one is the DISC itself has the ability to loan some of its income to the related supplier or the producer of export product, which is often necessary. And that specific loan is titled a producer loan. And the producer loan itself needs to be memorialized, it has to be written down, it has to be executed. And it has to have a very specific maturity date within five years. And it needs to be designated as a producer alone at the time that it's made. And so that can't really be an afterthought, it needs to be planned out ahead of time.
Dave: Okay. Well, thank you. Sounds like some useful tips for people who either have a DISC already or who aren't considering the formation of one. Any other sort of pitfalls or landmines that people unintentionally fall into that come to mind with the DISC?
Brandon: I don't know. The DISC being as complex as it is, there's many ways that I think you could misunderstand, if you don't have some good direction ahead of time. Just why I think it's very important to have somebody like yourself, as I understand you do a good job of instructing your clients as to, sort of the general rules of what a DISC is, and then directing them to somebody that can give them really specific answers on the legal questions. But it's a good idea to have that upfront.
One of the things that we do when we form a DISC is, we put together an operating memorandum. This is a document that really in very, as simple as you can get with complex terms and code sections that will lay out the rules, the expectations, areas that you should be aware of, there are very specific distribution requirements, and there are some timing issues. And so we put that down. And we try to help our client understand what some of these are, so that at least they have an expectation ahead of time. It's equally important to have someone who understands the return preparation and the accounting side of it as well.
So just in general, for a company that has a DISC or is planning on having a DISC, they need to really make sure they have somebody in their corner that that understands these rules and can help keep them on track so that they can continue to take benefit of those tax savings that are involved there.
Dave: Okay, well, thank you. That's very insightful and helpful. Well, as we're nearing the end of our talk here today, what do you think the future of the DISC is? It seems like the DISC has been, "going away". It's practically since its inception, or certainly from the '80s. So what are your thoughts? Is that is it? Is it really going away? And maybe another way to answer might be, what are some of the reasons to think that the DISC might last another five-plus years? And conversely, what might be some reasons that it might not last another five years?
Brandon: It is so very difficult to tell. I hear that about a lot of different taxing structures where we think that it might go or it might stay. And on the one sense, it's hard to know what is going to motivate the next tax law change. Certainly, we've seen a huge tax law change that just came through. And, in fact, there was an opportunity for Congress senate put on their changes for the tax cuts and jobs act before it was passed. They actually put the DISC on there to have it repealed. It's not entirely clear why there are some comments, but I personally, I think that in an effort to try to maybe appease the general public and the younger generation, they were putting on items on the block that seem maybe arcane, and in a way to try to retrieve some tax savings from the taxpayers, they put it on there.
But the reality is they had their chance, it was on the chopping block, they took it off specifically. And at the last minute, they remove the DISC from there. So it's still very much in existence and very much a viable option. I guess one could say, it looks like they're considering not using it. But I would argue that the need for the United States to have viable tax options towards export activity is crucial. And it's one that has always been around, the original intention for having a DISC was to incentivize export activity. And especially with the growth in our economy today, the export, despite any of the trade wars that are occurring currently, you're not going to get away from export activity. And if ever, there was something that could help boost jobs and US revenue, the DISC is an excellent incentive for that.
Dave: Okay.
Brandon: I think that's one reason why it will stick around for many years to come.
Dave: Okay, well, thank you for that insight. And thank you also for the context that it's not just the DISC in particular, but really any part of the tax code. It's hard to have a definitive crystal ball as to the future or nature of it, because tax law changes, and sometimes it's maybe not expected. So thank you for that.
Dave: Well, so I think to wrap up, I'm looking at my notes here. So early on, you talked about just in general with tax, you had to two tips that seemed very helpful. One is, do not ignore a tax notice. If you ignore it, it does not necessarily mean it's going to go away. In fact, it sounds like just the opposite. It just gets worse. And then the second one you'd mentioned is when considering a business transaction, really consider the tax consequences and tax structure on the front end. Did I capture your sentiments on those two points?
Brandon: Yeah, absolutely.
Dave: Okay. And then we drilled into the DISC in particular, and you had some tips there around really being careful to follow the rules of the DISC, that there are some very specific timing rules and deadlines that with other corporate structures might be more relaxed, but with the DISC there perhaps more strict, but on the other hand, the substance over form doctrine, on the other hand, is sort of relaxed, that sounds like with the DISC as compared to other structures.
Brandon: Yes, yes. And I realize that it can seem daunting to dive into any tax issue. And maybe that's why I enjoyed it field of tax as I do, because it is challenging, but any business is going to face challenges. And there are regulations in every industry and tax is just one part of it, but it is a big part of it. And any opportunity to maximize your tax savings is definitely worth considering and looking into.
Dave: That's excellent. Well, if any of our listeners want to reach out to you, or they have they're considering a DISC or you have a DISC and have questions, are you generally amenable to receiving a brief communication like that from people if they have an issue or question?
Brandon: Yeah, absolutely. We're certainly very happy to receive questions and calls from anyone.
Dave: So what's the one phone number should somebody use to reach you?
Brandon: Yeah, we can be reached... the number for Cantrell & Cantrell is (713)-333-0555. And that's our general line. I don't have a direct line out of that, but so someone-
Dave: What's your email? Now go ahead and repeat the number again.
Brandon: Yes. (713)-333-0555. Our web address is, cctaxlaw.com and so our email addresses are all @cctaxlaw.com. And they're typically our first initial and our last name. Mine is bfrenza@cctaxlaw.com.
Dave: That's excellent. Well, thank you for that. And we appreciate your willingness to field inquiries from folks. I mean, obviously, if it turns into a full blown engagement, that's another story. But we appreciate your willingness to feel the preliminary call as it relates to the DISC or really any other tax controversy matters, is that correct?
Brandon: Absolutely, yeah. Well, I appreciate the opportunity to get on and talk a little bit about the subject. Thank you very much for having me.
Dave: All right. Well, thank you, Brandon. And have a great day.
Brandon: You too. Thank you.
Dave: All right. Bye.