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Research and Development › Tax Credits › Tax Court

Miller Canfield

Are Wages for Research Credit Purposes Limited to “Reasonableness?”

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Smith v. Commissioner, a pending research credit case in the United States Tax Court, presents an issue of first impression: Is a partner’s self-employment income in a partnership allowable as a qualified research expense...more

Miller Canfield

Some Research Credit Good News and Potentially Much Bad News

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Over an objection by the IRS, the Tax Court recently ruled in Kapur v. Commissioner that it could limit discovery and permit statistical sampling of voluminous data related to a claimed research credit. The court refused,...more

Miller Canfield

In a Pending Research Tax Credit Case the IRS Fails to Follow Regulatory Language

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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

Miller Canfield

Tax Court Denies Research Credits for Research Activities

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A recent Tax Court decision - which arguably is wrongheaded - could cause many suppliers of production parts to original equipment manufacturers to lose federal income tax credits. Suppliers are well advised to consider...more

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