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

Roger Jones, Andrew Roberson and Jeffrey Glassman wrote this bylined article on a plaintiff request that the Supreme Court review the Fourth Circuit’s decision that the Administrative Procedure Act does not apply to the Internal Revenue Service Notices of Deficiency. If it decides to hear the case, the authors wrote, “The Court’s opinion could have major ramifications on both the IRS and taxpayers regardless of the outcome.”