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Court Tackles Hubzone Issues In Two Cases

Client Alert | less than 1 min read | 04.12.05

In Mark Dunning Industries, Inc. v. U.S. (Mar. 4, 2005), the Court of Federal Claims, after finding it has jurisdiction to review a SBA protest decision of a bidder's HUBZone qualification, decided that the SBA had appropriately found the bidder qualified because its "principal office" (which was in a HUBZone) was different from its headquarters (which was not). In Manson Construction Co. v. U.S. (Mar. 14, 2005), the court validated award to the second-low bidder which won because of application of the HUBZone preference, while also upholding the agency's revision of its internal estimate that brought the contractor within the "zone" of permissible cost.

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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....