In 2020, Thomas wrote a lone dissent in the Supreme Court's rejection to hear "Baldwin v. United States", a case involving the Internal Revenue Service (IRS) and its interpretation of policies. Lower courts had ruled in favor of the IRS in light of "Brand X". Thomas, who had authored the original "Brand X" majority opinion, wrote in the dissent that "Regrettably, "Brand X" has taken this Court to the precipice of administrative absolutism. Under its rule of deference, agencies are free to invent new (purported) interpretations of statutes and then require courts to reject their own prior interpretations." and had suggested that the Court should revisit "Brand X" as he sees it now "to be inconsistent with the Constitution, the Administrative Procedure Act (APA), and traditional tools of statutory interpretation."