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Deficient Notices of Deficiency and the Remedy Question

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

Tax Procedure

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QinetiQ comprises teams of dedicated people; experts in defence, aerospace, security and related markets. We draw on our extensive technical knowledge and intellectual property to provide the know-how and support to solve some of the world’s most challenging problems.   401 more words