AI, Sales‑Factor Apportionment and Mentorship: Mark Sommer on Tax’s Future

Mark Sommer, head of the tax, benefits and estates practice at FBT Gibbons in Louisville, Kentucky, shares his view on the most pressing issues confronting tax professionals in 2026.

**Artificial Intelligence as a Double‑Edged Sword**

Sommer says AI is the biggest challenge, both internally—shaping how tax teams operate—and externally, as government agencies adopt AI for audits, risk assessment, and discovery. He notes that AI introduces cost pressures, complicates documentation, and raises confidentiality concerns, signaling a new paradigm in tax and law.

**The Sales‑Factor Apportionment (SSF) Storm**

In state and local tax, Sommer urges vigilance over emerging SSF cases nationwide. SSF, a sales‑centric apportionment method intended to spur local economic development, often skews tax burdens against multistate businesses. By ignoring payroll and plant factors, it can inflate state tax liabilities for many firms. Sommer warns that forthcoming legislation will directly address these disputes, and corporate taxpayers must stay alert.

**Mentoring the Next Generation**

Sommer stresses the importance of daily mentoring, especially as AI and rapid practice changes leave new tax attorneys uncertain about the unknowns. He believes that passing on expertise is essential to preserve the craft.

**Early‑Career Wisdom**

A key lesson from Sommer’s 40‑year career is that a client’s risk tolerance cannot be inferred from demographics or superficial observations. Understanding the client’s true risk appetite leads to more reasoned, tailored advice.

Sommer’s insights highlight the evolving landscape of tax practice—where technology, policy shifts, and human mentorship intersect to shape the profession’s future.