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Searching Content indexed under Litigation, Mediation & Arbitration by Roger Jones ordered by Published Date Descending.
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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.
United States
4 Nov 2016
2
3M Company, IRS File Reply Briefs In "Blocked Income" Case; Tax Court Orders Oral Argument
3M returns to its argument that Treas. Reg. § 1.482-1(h)(2) is "procedurally invalid" because Treasury and the IRS failed to satisfy the requirements of section 553 of the APA when they promulgated the regulations.
United States
8 Sep 2016
3
Law School Professors File Amicus Briefs In Support Of Commissioner's Position In Altera
One group of six professors first notes its agreement with the arguments advanced by the government in its opening brief.
United States
5 Aug 2016
4
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 the US Department of Labor under the Fair Labor Standards Act.
United States
6 Jul 2016
5
Commissioner Files Opening Brief In Ninth Circuit Appeal Of Altera
The Commissioner's arguments on brief are very specific to the context of Reg. §§ 1.482-1(b)(1) and 1.482-7.
United States
6 Jul 2016
6
IRS Issues New Procedures To IRS Appeals For Requesting Assistance From Exam In Docketed Tax Court Case
Under the new procedures, Appeals will send a request for Exam's assistance if Appeals determines that the new information merits additional analysis or investigation.
United States
4 Jul 2016
7
Statute Of Limitation: Congress Overrules Home Concrete And Retroactively Removes Some Taxpayer Defenses
On July 31, 2015, President Barack Obama signed the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 (H.R. 3236; Pub. Law No. 114-41) (the 2015 Act) into law.
United States
20 Aug 2015
8
Altera: Tax Court Invalidates Section 482 Regulation On Administrative Law Grounds
In Altera, the U.S. Tax Court invalidated regulations under Section 482 requiring participants in qualified cost-sharing agreements to include stock-based compensation costs in the cost pool to comply with the arm's-length standard.
United States
20 Aug 2015
9
Court Weighs In On Deadline For Filing FTC Refund Claims
The U.S. Court of Federal Claims issued its opinion in Albemarle Corp. v. United States, No. 12-184T, holding that it lacked jurisdiction over the taxpayer’s claim for refunds.
United States
15 Oct 2014
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