Taxpayers had mixed success in two recent research credit cases in the United States Tax Court.
In Smith v. Commissioner, the taxpayer was an architectural firm....more
Congress perhaps made an unintended drafting error in the Tax Cuts and Jobs Act (TCJA) when it required a taxpayer to decrease its deduction for research and experimental expenditures....more
The stream of cases challenging disallowance of research tax credits continues in the Tax Court with Phoenix Design Group, Inc. v. Commissioner. The taxpayer in Phoenix Design designs mechanical, electrical, and plumbing...more
A recent United States Tax Court decision raises a high bar for taxpayers claiming federal income tax credits for research expenses. The case turned on whether the taxpayer proved that "substantially all" of its research...more