Tax Court's Scorched-Earth Opinion Disallows Research Credits for Dress Design Activities | Miller Canfield
To embed, copy and paste the code into your website or blog: For practitioners advancing research credit claims, a recent Tax Court case is of concern because it said more than was necessary to reject the taxpayer's claim. The Commissioner may seize upon dicta in the opinion to disallow other taxpayers' research credit claims. To claim federal income credits for research activities, a taxpayer must prove that it conducted "qualified research." Research is qualified if it satisfies a four-part test. Part One requires the taxpayer to prove that, at the outset of the research project, its prop...
Source: jdsupra.com