Because that's what she did last year. Yes lawyers, accountants get insulted too, and the worst insult that can ever be hurled at us is to be called a business historian. Or at least that's what I used to think. Cutting edge ideas are great. But who is going to help you decide when you've gone over the edge? That's right, it's us.
Based on my historical observations, tax cases often end up in court for one of two reasons: Either someone had a cutting edge idea the taxing authorities didn't like, or someone took a bleeding edge position (knowingly or not) and is now backed into a corner. Sometimes the taxpayer is lucky enough to get out of the corner, but as most lawyers know (I'm one as well so I get twice the insults), bad facts make bad law, sometimes overturned on appeal, but always making headlines (not of the NY Times variety but more along the lines of State Tax Notes).