Recognizing the need for clearer standards regarding the degree of deference that the federal courts should confer on guidance issued by the Department of Treasury and the Internal Revenue Service, the Tax Section created a Task Force on Judicial Deference in 2000. Based on the agency-by-agency approach required by the Supreme Court in United States v. Mead Corporation (2001), the Task Force analyzed the differences in the degree of authority and degree of deliberation underlying the various forms of such guidance and the impact of those differences on whether, and to what degree, judicial deference is appropriate. The Task Force recognizes that in light of Mead, there is a need for an agency-by-agency consideration of the extent to which courts should give deference to administrative pronouncements under the mandate of Chevron v. Natural Resources Defense Council (1984), which instructs a reviewing court to accept certain administrative interpretations rather than to impose its own interpretations when Congress has not spoken to the precise question at issue.