In this episode of Ropes & Gray’s podcast series Disputing Tax, Franziska Hertel, an associate in the tax practice, is joined by Kat Gregor, a tax partner and tax controversy group co-founder, and Brittany Cvetanovich, counsel in the tax practice, to discuss a recent Federal Circuit case, Charleston Area Medical Center, Inc. v. United States, and the interaction between that case and the brand-new proposed regulations on the so-called “three-year carried interest” rule in section 1061 of the Code.