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Supreme Court Denies Stolt-Nielsen's Certiorari Petition Challenging the DOJ's Decision to Prosecution

Client Alert | less than 1 min read | 10.31.06

The Supreme Court denied Stolt-Nielsen's cert petition challenge the Department of Justice's Antitrust Divisions' decision to prosecution the corporation which had previously been granted immunity exchange for its cooperation in an antitrust investigation. Stolt-Nielsen had initially received leniency in exchange for providing information in the alleged customer allocation and bid-rigging in the liquid-cargo shipping market. The Antitrust Division later decided to lift the immunity when it decided Stolt-Nielsen had not lived up to the immunity agreement. After the Court's decision, Stolt-Nielsen announced that it will file a motion to dismiss the indictment based upon the amnesty agreement, on Nov. 22, in U.S. District Court in Philadelphia.

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Client Alert | 3 min read | 10.10.25

New Post Appeals Mediation Pilot Program

On October 1, 2025, the IRS Independent Office of Appeals launched a two-year pilot program to make Post Appeals Mediation (PAM) more attractive and accessible to taxpayers. See IRS Announcement 2025-10. The new PAM pilot program offers taxpayers the opportunity to be assigned to a new Appeals team, which is otherwise unconnected to the underlying case, who will represent the original Appeals team in the mediation session. The assignment of the new Appeals team does not begin a new appeals process but rather is intended to help facilitate an expedited and impartial look at the underlying case with the goal of further exploring all potential paths to resolution prior to litigation....