By: Leandra Lederman

In QinetiQ v. Commissioner, the Court of Appeals for the Fourth Circuit refused to invalidate a Notice of Deficiency that simply stated „that QinetiQ ‘ha[d] not established that entitled’ to a deduction ‘under the provisions of § 83.’“ The taxpayer had argued that the Notice „failed to provide a reasoned explanation for the agency’s final decision, as required by the Administrative Procedure Act (APA), … 998 more words