QinetiQ Tests APA’s Application to Tax Deficiency Notices

Overview


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.