WINSTON-SALEM, N.C.—The US Court of Appeals for the Fourth Circuit recently upheld an IRS decision to reject a claimed $118 million salary and wage deduction by QinetiQ US Holdings Inc. Womble Carlyle attorney Mike Cashin discussed the ruling, and its implications, with North Carolina Lawyers Weekly.
A 2009 Notice of Deficiency from the IRS to QinetiQ was at the center of the dispute. While the IRS provided no explanation, it said in the Notice of Deficiency that the company had not established that it was entitled to the deduction.
Cashin told N.C. Lawyers Weekly that the IRS has a great deal of leeway in how it handles Notices of Deficiency.
“But there has been a couple of cases on this issue,” Cashin said. “I wouldn’t be surprised to see taxpayers push to have the law changed in the future.”
Click here to read “IRS Need Not Explain Rejection of a Deduction” in N.C. Lawyers Weekly (subscription required).
Mike Cashin concentrates his practice on all areas of federal and state tax matters. He has substantial experience advocating for clients in matters adverse to the Internal Revenue Service and the North Carolina Department of Revenue. Cashin practices in Womble Carlyle’s Winston-Salem office.