{"id":"AIBD-0833","title":"The US Tax Court let two taxpayers answer an IRS discovery request with predictive coding, crediting an estimate of $80,000 to $85,000 in review costs","summary":"In September 2014 the US Tax Court allowed predictive coding over the IRS's objection. It credited an estimate of 200,000 to 400,000 documents to review at $80,000 to $85,000.","date_observed":"2014-09-17","date_basis":"source publication","date_precision":"day","benefit_status":"intended","source_collection":null,"source_entry":null,"account":"The Commissioner of Internal Revenue asked Dynamo Holdings and Beekman Vista to produce the data on two backup tapes. The taxpayers said that a full review for privileged and confidential material would take many months and cost at least $450,000. They asked to use predictive coding, which the Commissioner called an unproven technology. On 17 September 2014 Judge Ronald L. Buch held that the taxpayers must respond and may use predictive coding. He wrote that predictive coding is an expedited and efficient form of computer-assisted review. The taxpayers' expert estimated that 200,000 to 400,000 documents would need review at $80,000 to $85,000. For the Commissioner's approach he estimated 3.5 million to 7 million documents at $500,000 to $550,000. The court found his opinion credible and uncontradicted. The review had not run, and the court left the Commissioner free to challenge the result.","category":"benefit created","unexpected":false,"purpose":"A vendor that the opinion does not name built the predictive coding software to predict which documents answer a discovery request, after learning from a small coded sample.","system":"Predictive coding","model_version":null,"developer":"Not named in the opinion","deployer":"Dynamo Holdings Limited Partnership and Beekman Vista, Inc. 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It credited an estimate of 200,000 to 400,000 documents to review at $80,000 to $85,000.","account":"The Commissioner of Internal Revenue asked Dynamo Holdings and Beekman Vista to produce the data on two backup tapes. The taxpayers said that a full review for privileged and confidential material would take many months and cost at least $450,000. They asked to use predictive coding, which the Commissioner called an unproven technology. On 17 September 2014 Judge Ronald L. Buch held that the taxpayers must respond and may use predictive coding. He wrote that predictive coding is an expedited and efficient form of computer-assisted review. The taxpayers' expert estimated that 200,000 to 400,000 documents would need review at $80,000 to $85,000. For the Commissioner's approach he estimated 3.5 million to 7 million documents at $500,000 to $550,000. The court found his opinion credible and uncontradicted. The review had not run, and the court left the Commissioner free to challenge the result."}},"provenance":{"kind":"legacy_record","basis":"Editorial assignment.","record_fields":["summary","account"],"source_refs":[]},"review_state":"record_mapped","coverage":"partial"},"systems[].autonomy_permissions":{"state":"unresolved","provenance":{"kind":"curatorial","basis":"Editorial assignment.","record_fields":[],"source_refs":[]},"reason":"This is an explicit unresolved assignment: the sources on record do not settle this question.","review_state":"not_assessed","coverage":"partial"},"systems[].component_role":{"state":"unresolved","provenance":{"kind":"curatorial","basis":"Editorial assignment.","record_fields":[],"source_refs":[]},"reason":"This is an explicit unresolved assignment: the sources on record do not settle this question.","review_state":"not_assessed","coverage":"partial"},"systems[].deployment_configuration":{"state":"unresolved","provenance":{"kind":"curatorial","basis":"Editorial assignment.","record_fields":[],"source_refs":[]},"reason":"This is an explicit unresolved assignment: the sources on record do not settle this question.","review_state":"not_assessed","coverage":"partial"},"systems[].inputs_outputs":{"state":"unresolved","provenance":{"kind":"curatorial","basis":"Editorial assignment.","record_fields":[],"source_refs":[]},"reason":"This is an explicit unresolved assignment: the sources on record do not settle this question.","review_state":"not_assessed","coverage":"partial"},"systems[].model_name":{"state":"unresolved","provenance":{"kind":"curatorial","basis":"Editorial assignment.","record_fields":[],"source_refs":[]},"reason":"This is an explicit unresolved assignment: the sources on record do not settle this question.","review_state":"not_assessed","coverage":"partial"},"systems[].model_version":{"state":"unresolved","provenance":{"kind":"curatorial","basis":"Editorial assignment.","record_fields":[],"source_refs":[]},"reason":"This is an explicit unresolved assignment: the sources on record do not settle this question.","review_state":"not_assessed","coverage":"partial"},"systems[].product_name":{"state":"value_present","value":{"kind":"record_fields","fields":{"system":"Predictive coding"}},"provenance":{"kind":"legacy_record","basis":"Editorial assignment.","record_fields":["system"],"source_refs":[]},"review_state":"record_mapped","coverage":"partial"},"systems[].provider":{"state":"unresolved","provenance":{"kind":"curatorial","basis":"Editorial assignment.","record_fields":[],"source_refs":[]},"reason":"This is an explicit unresolved assignment: the sources on record do not settle this question.","review_state":"not_assessed","coverage":"partial"},"taxonomy_crosswalks[]":{"state":"unresolved","provenance":{"kind":"curatorial","basis":"Editorial assignment.","record_fields":[],"source_refs":[]},"reason":"This is an explicit unresolved assignment: the sources on record do not settle this question.","review_state":"not_assessed","coverage":"partial"},"title":{"state":"value_present","value":{"kind":"record_fields","fields":{"title":"The US Tax Court let two taxpayers answer an IRS discovery request with predictive coding, crediting an estimate of $80,000 to $85,000 in review costs","headline":"Tax Court lets taxpayers use *predictive coding* over IRS objections"}},"provenance":{"kind":"legacy_record","basis":"Editorial assignment.","record_fields":["title","headline"],"source_refs":[]},"review_state":"record_mapped","coverage":"partial"},"version":{"state":"value_present","value":{"kind":"identifiers","identifiers":["e4fce78e6c85220c4d00997156bbd2a55b73dc1c20fbfd6b4f2419bbe6a8cab2"],"role":"SHA-256 of the complete public record and its assessments"},"provenance":{"kind":"curatorial","basis":"SHA-256 of the public record, its assessments, and its displayed answers and notes, excluding its own identifier and the derived coverage summary.","record_fields":[],"source_refs":[]},"review_state":"record_mapped","coverage":"complete"},"workflow":{"state":"value_present","value":{"kind":"record_fields","fields":{"account":"The Commissioner of Internal Revenue asked Dynamo Holdings and Beekman Vista to produce the data on two backup tapes. The taxpayers said that a full review for privileged and confidential material would take many months and cost at least $450,000. They asked to use predictive coding, which the Commissioner called an unproven technology. On 17 September 2014 Judge Ronald L. Buch held that the taxpayers must respond and may use predictive coding. He wrote that predictive coding is an expedited and efficient form of computer-assisted review. The taxpayers' expert estimated that 200,000 to 400,000 documents would need review at $80,000 to $85,000. For the Commissioner's approach he estimated 3.5 million to 7 million documents at $500,000 to $550,000. The court found his opinion credible and uncontradicted. The review had not run, and the court left the Commissioner free to challenge the result.","replication":{"produced_by":["The taxpayers restored the backup tapes and removed system files and duplicate messages.","The parties were to agree on search criteria for the review.","Coding a small sample of documents trains the software to predict relevance."],"must_hold":["The responding party works with the requesting party's counsel or experts on a search they accept.","The requesting party can move to compel if the response proves incomplete."],"echoes":[]}}},"provenance":{"kind":"legacy_record","basis":"Editorial assignment.","record_fields":["account","replication"],"source_refs":[]},"review_state":"record_mapped","coverage":"partial"}},"summary":{"total":91,"addressed":91,"known":28,"reviewed":2,"reviewed_complete":2,"reviewed_partial":0,"record_mapped":26,"review_not_assessed":63,"not_assessed":0,"complete":false,"by_state":{"value_present":28,"not_reported":0,"unresolved":63,"not_assessed":0,"not_applicable":0,"withheld":0,"source_unavailable":0}}},"presentation_version":"597578ff376e1418f5b3c89d838de6c08b23add69cd65864208bd101906260fa"}