Last week in Dynamo Holdings et al. v. Comm’r of Internal Revenue, 143 T.C. No. 9, the U.S. Tax Court became the latest court to approve the use of predictive coding in litigation. The scenario addressed by Judge Buch has become familiar: Faced with the review of a large volume of documents for potential production, the producing party (Dynamo) sought to use predictive coding to identify responsive documents; the requesting party (the IRS) opposed the approach.