QinetiQ Tests APA's Application to Tax Deficiency Notices | McDermott Skip to main content

QinetiQ Tests APA’s Application to Tax Deficiency Notices

QinetiQ Tests APA’s Application to Tax Deficiency Notices

Überblick


Roger Jones, Andrew Roberson and Jeffrey Glassman wrote this bylined article on the Fourth Circuit QinetiQ case, in which a taxpayer argued that an IRS notice of deficiency was arbitrary and violated the Administrative Procedure Act. The authors wrote that the case “would have far-reaching implications” if the court upheld the taxpayer, and “it is unknown how many notices of deficiency might be invalidated” by such a decision.