I. Introduction As the IRS’s attorney fee deferral enforcement campaign gathers national attention, legal and tax professionals are revisiting the foundations of fee deferral jurisprudence. At the heart of this discussion stands Childs v. Commissioner, 103 T.C. 634 (1994), aff’d, 89 F.3d 856 (11th Cir. 1996), the seminal Tax Court case that validated the deferral...