Resolving Old Audit Issues
Client Alert | 1 min read | 11.08.10
On October 29, DCMA and DCAA announced a joint initiative to "disposition" approximately 400 "reportable audits" and 300 Form 1s that are awaiting ACO action. Based on our experience, many of these unresolved audits and Form 1s are likely to raise issues that the ACO and the DCMA lawyers recognize to be without merit, but that the ACO has been unwilling to close because the ACO cannot or will not try to obtain approval to reject the DCAA position by going through the DCMA Board of Review process, so this initiative is likely to result either in the issuance of a large number of non-meritorious final decisions or politically dangerous decisions to overrule the DCAA audit position -- and bad final decisions may be more likely as a practical matter than disagreeing publicly with the auditors.
Insights
Client Alert | 4 min read | 02.20.26
SCOTUS Holds IEEPA Tariffs Unlawful
On February 20, 2026, the Supreme Court issued a pivotal ruling in Trump v. V.O.S. Selections, negating the President’s ability to impose tariffs under IEEPA. The case stemmed from President Trump’s invocation of IEEPA to levy tariffs on imports from Canada, Mexico, China, and other countries, citing national emergencies. Challengers argued—and the Court agreed—that IEEPA does not delegate tariff authority to the President. The power to tariff is vested in Congress by the Constitution and cannot be delegated to the President absent express authority from Congress.
Client Alert | 7 min read | 02.20.26
Section 5949 Proposed Rule Puts the FAR Council's Chips on the Table
Client Alert | 5 min read | 02.20.26
Trump Administration Pursues MFN Pricing for Prescription Drugs
Client Alert | 4 min read | 02.19.26
Proposed NY Legislation May Mean Potential Criminal Charges for Unlicensed Crypto Firms
