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Court Explores New Frontier On The OCI Front

Client Alert | less than 1 min read | 10.17.07

In Axiom Resources Mgmt., Inc. v. U.S. (Sept. 28, 2007), the Court of Federal Claims held that an alleged unequal access to information organizational conflict of interest had not been adequately mitigated because, inter alia, the mitigation plan was not enforceable, as by court order. Also, before determining whether to issue an injunction, the court requested an amicus brief from the Federal Trade Commission Bureau of Competition on several issues, including whether the awardee should be required to divest several contracts, and whether non-disclosure agreements, perhaps similar to those typically involved in establishing appropriate firewalls, unduly restrict future competition.

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Client Alert | 3 min read | 07.13.26

Amici Rally Behind Liberty Global, Urging Tenth Circuit to Rein in Economic Substance Doctrine

Following the 10th Circuit's April 21, 2026, decision affirming the disallowance of Liberty Global’s $2.4 billion deduction under the codified economic substance doctrine, I.R.C. § 7701(o), Liberty Global filed a petition for panel rehearing or rehearing en banc on June 5, 2026. That petition has since drawn significant amicus support from various industry groups representing large taxpayers, as discussed below....