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Article

McDermott Will & Emery | USA | 13 Apr 2017

APA Challenge to Notice of Deficiency: QinetiQ Requests Supreme Court Review

On April 4, 2017, QinetiQ U.S. Holdings, Inc. petitioned the US Supreme Court to review the US Court of Appeals for the Fourth Circuit's decision

Article

McDermott Will & Emery | USA | 31 Oct 2016

APA Challenge to Notice of Deficiency: QinetiQ Oral Arguments

On October 26, 2016, the US Court of Appeals for the Fourth Circuit heard oral argument in QinetiQ U.S. Holdings, Inc. v. Commissioner, No. 15-2192

Article

McDermott Will & Emery | USA | 3 Aug 2016

Law School Professors File Amicus Briefs in Support of Commissioner’s Position in Altera

Two groups of law school professors have filed amicus briefs with the US Court of Appeals for the Ninth Circuit in support of the government's

Article

McDermott Will & Emery | USA | 6 Jul 2016

Supreme Court Issues Opinion Addressing Interplay between APA Procedural Compliance and Chevron Difference

In Encino Motorcars, LLC v. Navarro, Sup. Ct. No. 15-415 (June 20, 2016), the Supreme Court of the United States invalidated a regulation issued by

Article

McDermott Will & Emery | USA | 5 Jul 2016

Commissioner Files Opening Brief in Ninth Circuit Appeal of Altera

In Altera Corp. v. Commissioner, 145 T.C. No. 3 (July 27, 2015), the Tax Court, in a unanimous reviewed opinion, held that regulations under Section

Article

McDermott Will & Emery | USA | 5 Dec 2013

Challenging regulations after Mayo and Home Concrete

In the wake of the Supreme Court of the United States’ recent tax opinions in Mayo Foundation for Medical Education & Research v. United States, 131 S

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