Liberty Global

Yeah, there's a direct segue.

So Be Afraid, Liberty Global is exposing customers to AI agents.

Yeah, I mean, so what you were talking about with the voice interface thing is really relevant to this.

We've had chatbots in customer service-like conversations.

It's like they haven't- Yeah, still is now.

You go back a few years and it was pretty bad and it's got better.

So Liberty Global, which for people not familiar with it, the biggest thing they own, they kind of part own is Virgin Media O2 in the UK, but they also have a bunch of network assets in Europe, although they've been shrinking in recent years.

They've done a deal with a company called Sierra, whose founders are quite interesting.

And there's been a surge of economic substance arguments that the IRS has been racing against taxpayers.

And we're seeing some of those come through the courts, specifically the Liberty Global decision, which we talked about on this podcast several months ago.

How does this surge of economic substance argument raised by the IRS potentially relate to this invalidity argument?

Well, I think you're exactly right to bring up the Liberty Global case for this question, right? Because there you had a taxpayer who challenged the validity of a regulation and succeeded.

It was on procedural grounds, but succeeded in invalidating the reg in the 10th Circuit.

And then what we saw was the government filed a counterclaim months later asserting economic substance, right? So they said, we're not giving you the refund.

That's Liberty.

Liberty Global.

Yeah.

Liberty Global, the owner of VMOT, basically.

And that's right.

And that's about it, really, for opening bollocks to me.