Madam Policy Talks Tax, Justice, and Saying "Yes" With Judge Cary Pugh

Olivia Dunning: Hello everyone and welcome to Madam Policy. ⁓ I am here today with my good friend and colleague, Senior Tax Policy Counsel Kimberly Pinter. Welcome, Kimberly. Thank you, Dee. And ⁓ we have a very special guest today. We have a judge with us, Judge Kerry Pugh. And Kimberly, can I ask you to introduce the judge, please? Absolutely. It is a special privilege to have the opportunity to introduce US Tax Court Judge Kerry Pugh today. I've known Judge Pugh for almost three decades, and I often darkened her door when she worked for Senators Patrick Moynihan and Max Bacchus on the Senate Finance Committee staff. Of course, back then she was just Carrie. In developing tax policy, we frequently reach across the aisle, and the judge and I did that often. While we may have had some different perspectives on those policies, I have always had the utmost respect for her and enjoyed working with her. Judge Pugh has had a very interesting career, traveling full circle before becoming a tax court judge, beginning at Big Law, then serving as a Finance Committee staffer, doing a stint at the IRS, and then joining Big Law again before joining the tax court in December of twenty fourteen. You may be familiar with Judge Pugh's career path, but what you might not know is that she is an avid flyfisher. In fact, if you look up her LinkedIn page, the only tagline under her name is Fly fishing. More about that later. We look forward to talking with her today about her path and her current role and about the life events or influences that brought her here. Welcome, Judge Pugh. Well, thank you very much. It is a pleasure to be with you, Kimberly. I really appreciate those kind words. And with you meeting you today, Dee. Thank you. Yeah. But it's like we're kindred spirits because first of all, I grew up in Arkansas. So fishing is, you know, a thing that we do and I love doing it. So that's very exciting to know that you're a fisher person. ⁓ but also you and I both went to UVA law. And as I've told you ⁓ previously, you know, I would be remiss if I didn't know that my husband also went to UVA law. However, only two of the three of us are now judges. So at some someplace out there, an alumni association is is sighing because I feel like I've failed our UVA law alums. But ⁓ we're really thrilled to to have you here. And you know, serving on the United States tax court is really an amazing ⁓ feat. Congratulations on your work and thank you for your service. Can you give our listeners just a quick overview of the jurisdiction of the tax court? I'm happy to do that. ⁓ sometimes I like to call us the small claims court for tax. We get well over ninety percent of the federal tax cases that are filed in federal courts. We have jurisdiction over income tax disputes at the IRS, the way I explain it, cocktail tax. If the IRS says you owe more money, there's a few letters going back and forth, yes you knew, no I don't, yes you do, no I don't. And then ultimately the IRS will issue ⁓ what's known as a notice of deficiency or a 90-day letter if it's unable to be resolved. And at that point in the letter, the IRS explains that if you don't like it, you can go to the tax court before you pay, or you can go to federal district court or the court of federal claims after you pay and file a claim for refund. So our jurisdiction in that regard pretty well runs concurrent with the ⁓ federal district courts. We also get jurisdiction specially granted to us over interesting little areas like passport revocation. We also deal with collection cases, disputes over tax exempt status and ⁓ whistleblower cases, and it seems every n time we turn around somebody's thinking, ⁓ well, maybe we'll expand the tax court's jurisdiction. So there's always something new, just like Kimberly will tell you. There's always something new in tax. Can I ask one follow-up question? I didn't realize that you got whistleblower cases. i is that specific to IRS and tax? Are you are you saying that you have jurisdiction over a a greater jurisdiction over whistleblower cases in general? Good clarification. It is when the IRS has denied or ⁓ granted a smaller reward to ⁓ award to a whistleblower. But it's all tax. It's all tax all the time. I get it. I get it. That's fascinating. Thank you. I appreciate that. That is fascinating. I didn't realize your jurisdiction went so far. ⁓ But ⁓ within the realm of tax, I know the tax court's jurisdiction runs from the largest entities in the world arguing over billions of dollars down to the pro se individual defending him or herself over a much smaller amount. ⁓ what's c what kinds of cases do you find the most challenging or the most interesting within the realm of those you handle? I think there you can always find something interesting in most cases. I would say that is even true for the the tax protester cohort where they're just saying that the tax law is unconstitutional, etc. Hearkening back to our southern roots, D. A lot of times I'm focused on the story. So for the small taxpayers Everybody's got a story. And for the largest taxpayers, ⁓ sometimes those cases can be dry. Sometimes they can be interesting. A lot of times they're gonna have the the highest level of lawyer both from the IRS and from the the private bar where you'll have twenty lawyers say on each side, so you know you're getting their best, and so you wanna give it your best. ⁓ but equally when you don't have a lawyer's most of our cases, the taxpayer is unrepresented. So we really are a small claims court for tax. And in some respects, that puts more pressure on me because I want to make sure I get it right for the taxpayer and for the IRS when there's a small taxpayer. But a lot of our job is just getting them to tell a story and then, you know, the people will say the funniest things. I hope I don't say things terribly funny. live here today. Well, I want people to laugh and find it amazing. I want you to say funny things. Well, I'll do my best. But y never know what I'm gonna say on the transcript. And then that's true. You put people under oath and you just never know what they're gonna say. Well l you know, I I find that very interesting how it unfolds in court. But if I if I pull out, I find something else very fascinating about you personally and that and ⁓ Kimberly alluded to it earlier. And that's that throughout your career you've really spanned the full life cycle of law, right? You've created law in Congress or you've helped to create law in Congress. You've implemented the law in private practice. And now you're resolving disputed law. ⁓ I think that's a really unique set of experiences that really not everyone has the opportunity to to have. What have you enjoyed most in each of these types of experience and and and what have you learned or or what was the most challenging for you? Well, I will tell you a funny story. When I was on the hill working on a piece of legislation, I remember getting really frustrated because we needed to get the name of an an agency. It was a state agency. And it's like, okay, t telling the lobbyist for the the whatever the thing was, we need the n you know, they they offered it up, okay, and then they changed the name. We're like, Okay, well you gotta get the name right. And they kept changing the name. And then finally we're like, okay, we've got to get the name right. And then ⁓ enacted the provision. I go to the IRS and I'm in a meeting. And there are people in the meeting who were like, Who in the world drafted this thing? They can't even get the name of the agency right. And I'm like, whoa, whoa, whoa, whoa. I not my fault. Not my fault. I did it. I'll take some heat for some of the stuff we did, but no, I tr we tried. But the name of the agency was still wrong. So you see well, you see how things are done. We see how they're done well. ⁓ you see how much happens with less than perfect information, which is illuminating when then you go to and w apply the law and you realize that it's no wonder that there were some near misses because we really didn't know everything when we were enacting it. A lot of times things are done. in a hurry, if you have ⁓ you know, people who understand the process, like Kimberly, maybe I'd be told, no, here's the real deal. But when I got out off the hill, I remember being told by somebody, ⁓ we didn't really tell you what was going on. I'm like, well, why do you think you got a bad provision if you didn't tell me the real problem? Well, we would never go in and tell you what was going on. That same person said he would never come to see me without somebody who knew what they were talking about. And I was glad because, you know, that I wanted to talk to the tax director or somebody who knew what they were talking about, somebody o on the ground and and the the the the best in the business knew what they didn't know and would make sure they covered what we needed to know. ⁓ but I enjoy ⁓ I enjoyed all aspects of it. All aspects of it are hard. Mm-hmm. one thing that is very frustrating, and I think I just alluded to it is You have to be comfortable operating, knowing that you can't know everything, knowing basically that you're committing malpractice if you were in private practice because you really have so little information and so little time to reflect. But a lot of times the answer you have to give an answer. And the correct answer can be yes or no. Either way, because the parties just need an answer because it's a business. Problem or a personal problem, they will move on. They will adjust to whatever the answer is. The wrong answer is we'll tell you in a month. I'm not saying which month. We'll tell you in a year. We'll tell you forever. Now it's important to deliberate. I want to get things right. And and this is the job. It's unique in that I live in the the past. I get to get in the way back machine. I work on cases. We've got a few older cases. Cases get old in the tax court for a variety of reasons. Sometimes the IRS and the taxpayer agreed to extend the statute. So for example, somebody had a felony conviction, served time, got out. I'm dealing with those cases now. The year in issue is tw two thousand eight. What they're trying to remember what happened in two thousand eight. Yeah, that's hard. So it's so it's The case was filed in like twenty twenty four because that's when they finished the civil side work. ⁓ so now I have more time to reflect, but I'm living in the past and I'm suffering for, you know, faded memories, lost documents, etc. So that's w the one side. ⁓ the other side is it's just so interesting. Whether you're working on a policy question, that's very interesting. Whether you're trying to implement something efficiently so that The taxpayer and the IRS can live with it. So, you know, you can write the greatest theoretical answer and it's very impractical. So trying to find the practical answer, something that people will understand, something that more than say five people in the United States will be able to comprehend. And then private practice, it's like, you know, that's where the rubber meets the road. Tax administration and private practice, where you're you know, telling the taxpayers here's how this works. And then like I said, ⁓ now I get to sit back and reflect and see like where it all went wrong. And it is very funny when you're like, ⁓ yeah, I remember working on that before. Right. Right. And now it's come back. The chickens have come home to roost, as we say. Yeah. That is indeed the case. Yes. ⁓ the tax court has a really unusual history, having originally been an independent agency of the executive branch, and then being removed from the executive branch in nineteen sixty nine to be an independent court. Do we see evidence of that unusual history in its operation today? And how does the tax court fit in with the rest of the U.S. tax court or excuse me, with the rest of the U.S. court system? I know you alluded to a little bit of this earlier, talking about the concurrent jurisdiction, so love to hear a little more about that. We we are an interesting ⁓ little world into our own. ⁓ we were set ⁓ established in nineteen twenty-four trying to f to provide a convenient forum to resolve tax disputes. And because of that, we actually travel around the country. I don't know of other courts that travel around the country as much as we do. The Court of Federal Claims might travel. ⁓ but because we we started out more as an executive branch agency. ⁓ I think the way I think of that ⁓ manifesting itself today is one, we have a lot of unrepresented taxpayer, and we do think about it as small claims court for tax, which again really appeals to me. I get the stories that they they want to tell. ⁓ and two, the procedures are not as robust for the smaller cases. It's you know, bring your documents to court, meet with the IRS, and then you get a judge. rather than all of the ⁓ strict rules for discovery. We do have those and and we do apply those in the largest cases and we do have rules about exchanging documents even for the small taxpayers. But we're much more focused on let's try to get the documents in and is there a prejudice to the other side. And I've I've had situations where ⁓ I've found that the IRS behaved in a prejudicial manner and I've also where the taxpayer didn't share documents and it really hurt the ⁓ IRS. But because of that, we I think we're a little more relaxed and ⁓ it's a little easier for an unrepresented taxpayer to come in. We also ⁓ unique among federal courts, the ⁓ interests of the government are not represented by the Department of Justice. But rather are represented by IRS attorneys. On the other hand, we are our cases are appealed unless a taxpayer can elect a small case procedure where the case isn't appealed and it's more relaxed. Those are the small cases to which I alluded. Mm-hmm. But if it's a regular case, it it is appealed to the circuit to which an appeal would lie had the taxpayer filed their case in district court. District Court. So we go to all the different circuits. So if you're in Virginia, you would go to the Fourth Circuit. If you're in California, you're going to the Ninth Circuit. You know, pick your different circuits. ⁓ Miami, you go to the eleventh circuit. We owe all the different circuits around the country, so we can create on our own a circuit split. If we have two ⁓ two tax court cases, go to two different circuits and the two different circuit courts see a distinction. On the other hand, it it doesn't it it can happen. It doesn't happen all that often. ⁓ I am bound by the ⁓ cases that my colleagues ⁓ write and there's a a process by which we review ⁓ the opinions ⁓ of our colleagues and we are bound by them and we can discuss them in court conference when they're significant or perhaps we we don't all see eye to eye. ⁓ we often do. ⁓ but it's unusual for any trial court judge to be bound by yeah ⁓ a opinion of another trial court judge, but that's so that we are more uniform nationwide. And then again, the appeals courts do what appeals courts will do. And occasionally there'll be differences. Usually they're pretty minor. Some sometimes it'll be like is it a two part test or is it like a more holistic test? But you all typically get to the same place. So we've been talking about your jurisdiction and you know how your court operates and the kinds of cases that it has, but I want to take us back a little bit to before you became a judge, and that's going through your confirmation hearing. You know, I ⁓ I I read your opening statement, which I loved, ⁓ and it has a it has a real southern feel to it. And you know, you talk about that the law chose you. And I found that very sort of poetic. And also compelling. You also talk about the role of the influence of your mother, who had worked as a legal secretary ⁓ while you were growing up. I wondered if you could talk about both of those things. How did the law choose you? And tell us a little bit more about your mom's influence. So interestingly, my mother well, ⁓ there was a funny story about ⁓ another ⁓ lawyer in the her law firm saying, calling her by her maiden name and she was pregnant with me and a a a ⁓ a wonderful secretary said, ⁓ Mister, I'll leave out the name. I think it is time that you call her Mrs. Pugh because they were you know, it was a sensitive topic in the nineteen sixties. Yeah. ⁓ she when she had me, she stopped as a legal secretary. But I do remember we would go I think it was then downtown or it could have been on Langer Road, we would visit these lawyers. And so I don't really remember much more than that other than we would visit these lawyers. Mm-hmm. And it must have seeped in somewhere. Stuck in there. Whether it while mom was pregnant or or however, because I was on a little you know, they had those little kitty game shows. Yeah, yeah, yeah. So I was on this thing called Kitty College on Channel thirteen in Lynchburg, Virginia, and it was me and Patty Spagnola and Jimmy Watts. We were on this little kitty college game show and they would go around and he would ask questions. Mr. Stapleton would ask, you know, the little three little kids and we were, you know, it's like James River we had and I forget the other th three schools. You could only do it four times and if you won all four times you were undefeated, you had to retire. But they would ask the little kids what we wanted to be, and I wanted to be a lawyer. And mom and dad had no idea what I was gonna say. And apparently when the camera was off me I'm gesturing and I'm like imitating the director and I'm a I'm I'm I'm mortifying them. And the cameras won me and I'm perfectly fine. ⁓ but by the end of the four weeks, like Jimmy Watts would have all these sort of interesting things he would say. And by the end of the four weeks he's like, you know, do you still want to be a lawyer? I'm like, Yep. So I announced on a a third grade, like little kid game show that I wanted to be a lawyer when I grew up. And I I never really deviated from wanting to be a lawyer, the kind of lawyer I was I probably didn't understand at all. I also was interested in foreign affairs, ⁓ and ⁓ thought about, you know, the foreign affairs side, but the lawyer was the training, the path to that, and then was fortunate to to have a very good experience as a summer associate in a tax group. And that's how I ended up wanting to be a tax lawyer. I think I understood from that group how tax intersects with so many different areas and the policy side of tax intrigued me. And I I think I was bold enough to say b before I even had a a a job offer that I wanted to go to government bef yeah, so I don't even I'm a summer associate, I don't even have a job. And I'm telling them that I want to leave them. to go into government. Now I was very fortunate to work for some great people and they had actually been in government as well and they they valued it. And then they also were very supportive when I did express interest after a few years at that law firm. But it was very funny. So I was like, yeah, I just want to go into government. So I was a little bit bold, I would say, as a summer associate. I think it's great. I you know, being bold, especially when you're young, sometimes It's based on naivety or a little bit of ignorance. It was for me. I was quite bold, but I really didn't know any better. ⁓ it's good because then you try I think you try new things. I will note for the record that yet again I have failed because while you were on a game show as a child doing extraordinarily well, I was on the bozo show and messed up the one question that I was asked. So just just so we keep are we're keeping score here, Judge Pew, and you're winning, just so you know. Yeah, I bet your parents were still very proud. They were. I have the picture here somewhere. I will show it to you one day. And and they probably weren't as mortified as mine, where they probably they couldn't even watch. They had to stay home. Kimberly, do were you on any game shows as a child? I was not, but I was on the Bozo show one time when I was little as part of a birthday party. Okay. There you go. So there's that. But that's about it. So ⁓ so staying with your ⁓ opening statement before the committee, ⁓ you also laid out that your guiding principle is to ensure that the law is applied fairly and impartially. So within the context of the tax court, how do you apply that principle as a practical matter when you're hearing cases? I think the the biggest challenge we have, of course, is that we when we don't have lawyers representing the taxpayer, how can we make sure we're hearing the taxpayer side of the story and we're getting the facts out. The tax court is very fortunate to have strong support from pro bono clinics, whether they're ⁓ the the local clinics, whether they're academic, the IRS has a low income taxpayer clinic program. And invariably when I'm out on session, ⁓ when there's a regular session, There'll be somebody who shows up from a clinic so that a lawyer who show a taxpayer who shows up without a lawyer, I asked, Do you want to talk to the clinic? And most of the time they do. So they get a chance to talk to a lawyer who's not the IRS and not me. ⁓ it but you do not want to have the taxpayer lose because they don't have a lawyer, nor would I want the taxpayer to win because I am now their lawyer. So it's really about trying to make sure you get to the right answer, trying to get the facts out. And I would say in that regard, I think almost there are a few exceptions to the statement that the IRS lawyers generally are trying to get to the right answer. Now they're hearing one side of the story perhaps, but they're not trying to win the most money because they know, well, there's an appeals court and there's me. But they're really not trying to win. They're trying to get to the right answer. And they will quite often concede cases. We have a lot of cases that settle for no deficiency because the IRS and the taxpayer spoke. The taxpayer perhaps only understood after talking to the lawyer what the taxpayer needed to show the IRS to show why they don't owe the tax or whatever. ⁓ so you know, it's not just me trying to make sure we get to the right answer. But it's really about, ⁓ you can't really you can't care about the answer in the sense that you have to accept sometimes you're gonna get an answer you don't like. But if it's that's the law, the law is the law and that's the law and you just try to get the taxpayer to tell you their side of the story. You try to make sure if if there's anything that's bothering you, you have to be willing to ask it. particularly for the unrepresented taxpayers. Yeah. And, you know, you also give ⁓ enough ⁓ an enough leeway if if they're gonna sink their own battleship, you let ⁓ do it, particularly if they are unreformable protesters who say that the tax law is unconstitutional or or name your your list of amusing arguments. So something else that's complicated. ⁓ I want to talk about some of your other academic studies. And here I'm thinking about your work ⁓ with the Russian language. ⁓ you did your undergrad work at Duke, you studied Russian. I'd like to hear a little bit more about that. I did not study Russian, but my very first international trip ever from Conway, Arkansas was to Russia. And so I have a special place in my heart. I think it's a beautiful country. ⁓ and I loved being there. But w what was the impetus for that for you? What did you study? What do you continue to study today? I grew up in an era where we had Star Wars and the the the Soviet Union. It was an enigma b and the Russian history was fascinating, full of really outsized characters, including Peter the Great, who was outsized himself. But Peter the Great, Catherine the Great, Ivan the Terrible, some crazy stories. ⁓ and yet now we had ⁓ the Cold War and ⁓ you know, the nuclear talks and and mutual assured destruction and all that. And I just found that quite fascinating and in high school really focused on that, studied that, and it tied to again to wanting to be a lawyer but also interested in foreign service. Right. And I when I went to Duke started immediately with the Russian language, Russian studies and political science. Was fortunate enough to go to the Soviet Union while it was still the Soviet Union. Yeah. Not that it was fortunate that they were still the Soviet Union, but I got to see it ⁓ and I actually think it's not very different today. and I I just found the Russian people just to be fascinating. Their their hid history and their literature. And you can see echoes of that in how they approach things today, which I think is fascinating. Do you ⁓ do you are you reading anything right now? Are you reading anything about Russia? Do you read in Russian? I used to be pretty good in Russian. I wasn't great. I was pretty functional. And we I would read in Russian. I had courses in Russian where it was in the Russian language, we were doing like Soviet poetry, et cetera. Yeah. But it's just very hard to keep up if you're not around it. When I got out of ⁓ my graduate program and was working in Richmond, I tried to get a tutor, but it was just really difficult if you're not immersed in it. Well, thank you for entertaining my Russia exploration. I appreciate it. You've mentioned ⁓ fishing a few times, and I I find the whole idea of fishing very fascinating. As someone who grew up on the coast of Florida and literally have never fished. ⁓ I'm very curious about that, yes. And I know your ⁓ your social media feed, your ⁓ your Facebook pictures frequently ⁓ feature you holding some very large fish that you've caught. So I'm curious, like who taught you how to fish? When did you learn? ⁓ you what do you like to fish for? And do you like eating the fish as much as you like catching them? So I don't remember not fishing. I can't believe you didn't fish when you're surrounded by water, Kimberly, but Both parents grew up on I think we're gonna have to have an outing. We have to remedial something. Yeah. ⁓ both parents grew up on farms. So in the summers especially especially, but a lot of weekends we were just outside doing like playing outside. And I was often in water. If they put me near water, I was gonna get wet as little kid. And I don't remember not fishing. I think the earliest photo of me with a fish, I'm three and my sister's one or two. So we were fishing with my dad and my mother also fished but particularly with my dad because I think that way mom would just throw us out. But she loved to fish too. We would go out, get in the water, as learn to swim in our lake. And I don't remember not fishing. And as I got older I became more interested in fly fishing because ⁓ people were catching more fish that way and I wanted to catch more fish too. So I I fished throughout high school, ⁓ college, of course, it was harder to fish because you don't have all your stuff and there's college stuff. When I got back to Virginia, I knew what I was doing locally so I could do more go fishing more and and Charlottesville because I'm from not far from there, so I knew what I was doing. Then when I got up to the D C area, I connected with a a fly fishing guide who's a very close friend. ⁓ he and his wife and would go on trips. And I'm I love most any kind of fishing. ⁓ I have favorite places I've gone, which would be like Christmas Island, the jungle in Bolivia, wow, New Zealand. lately I've been going to Scotland with some very good friends that I met through fishing. Go to the far north of Scotland, the River Thurso, and I've been doing that now since twenty fifteen. In fact, I was supposed to go twenty fourteen. My friend said You're going. They didn't even ask. They just told me I was going. ⁓ but then ⁓ unfortunately my nomination hearing was smack in the middle of that trip. So I had to bail out like the Friday before. And ⁓ I I think I made the right choice because my friends on the hill said, Well, ⁓ they tried to avoid it, but then they're like, This is gonna be the best chance to make sure we get your hearing in, get you pending on the floor. to get you done. Yeah. And it was an elect it was a it was a a midterm election year. So I think they made the right call just to make sure I was in in line to be confirmed whenever they could move a package. But it didn't mean I missed my first trip and I went the next year and and just love that love getting outside, ⁓ getting in the water, wandering around looking around you see nature. ⁓ I think some people get a little too carried away with the fishing and the casting. And they don't they failed to kind of look around and enjoy whatever else is out there. ⁓ I think the movie that came out, the river runs through it. I was just gonna ask you about that. It really hyped the sport. I think it got a little oversold. And so then you had a retraction because stores couldn't support themselves. So now we're getting sort of right sizing. ⁓ it's a growing sport, particularly for women. ⁓ you can get out. There's some great ⁓ programs, casting ⁓ for recovery for breast cancer survivors because you get in and you move your shoulders, you move your arms. Fabulous programs that ⁓ they offer. But you just get outside and you and whatever kind of thing you can do to get outside, I think is is well worth doing. And ⁓ it's something was great during COVID because you're waving around a stick that's nine feet long with a hook on the end and a line with the hook. So that engulf because you're swinging things, no one's getting within six feet of anybody. Yeah. When when you're swinging things distance built in. Natural distance and you're outside and and I have found it to be refreshing. I wish I could do it a lot more than I get to do now, but I found it to be ⁓ quite ⁓ restorative. Well that's great. And I that's really interesting about ⁓ classes, you know, or training for breast cancer survivors. We've focused on breast cancer survivors before on Madam policy and different ways that people adjust and and deal with breast cancer. So that's that's excellent. Thank you for sharing that. ⁓ so you've given great advice so far, but now I'm going to end this episode the way we end all of our Madam Policy episodes, which is what advice would the Fisherwoman extraordinaire Russian speaking Judge Pugh give to her 24 year old self? You know, it's it's funny you should ask, ⁓ because I keep thinking ⁓ my office, I tell ⁓ you need to watch Star Wars, The Princess Bride, to be able to to discuss things with me. ⁓ there's a few movies, there's a few references that come out, s ⁓ Saturday Night Live references. But I think the the one that I'm thinking of here is, you know, keep your mind on the present. And so when Yoda's fussing about Luke, never his mind on where he is, what he is doing. always looks to the future. So I think it's it it enjoy the present. Yeah. And don't get too carried away about the future. I don't think I did a terrible job, but I think it bears emphasizing as well to ⁓ be willing to try things. You know, just say yes. Don't worry about, you know, plotting your next steps for don't think five steps ahead. ⁓ doesn't always have to be the greatest you know, clear path to career advancement. You just never know, you know, what's gonna come out of it just by saying yes to something different. ⁓ and I think the ⁓ final piece, which is I think, well, two more pieces which are more ⁓ serious would be ⁓ well, anybody can be a mentor. Some are show you how to behave and other people show you now how not to behave. But you know, you're very fortunate if you're being paid As long as you're learning. Just think how much you paid for your own education and now you're being paid to learn. How terrific is that? And it's really you're the only person guarding your own reputation. So that is the thing you need to guard very carefully and associate yourself with good people. I'm I'm just writing them all down, in case in case you're wondering what I'm doing. I'm scribbling them all down. I think those are excellent, ⁓ w words of advice, just say yes is something that we talk about ⁓ a lot here on Madam Policy, but also in in our group. But I just have to say I you must also always say from the Princess Bride, that word does not mean what you think it means, particularly being a judge. That is the one that I use all of the time. Yes. Well and then I also quote my cousin Vinny on the the the to explain what an expert is or is not. But yes, I mean yes, incon inconceivable ⁓ nobody Should use that in court because I think it'll get you in it'll be a r rich target for the Princess Bride quote. Well, I love it. Thank you very much ⁓ for being on the show today, Judge Pugh. I know your time is incredibly precious, and so we are grateful for all the time that you spent with us. Thank you. Of course it was a pleasure. Thank you. Thank you.