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Turn Square Corners or Sit on Sideline

Client Alert | less than 1 min read | 01.09.12

The Federal Circuit in Digitalis Educ. Solutions, Inc. v. U.S. (Jan. 4, 2012) emphasized that a company wanting to protest must itself satisfy the stipulated process. In this case, the company lost its right to complain of a sole-source award to a competitor because it did not routinely check FedBizOpps, where the agency published a notice of the proposed award, or submit its own statement of capability to show it could do the job, as the notice in FedBizOpps required.

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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....