by Bruce Warner | Feb 12, 2021 | Blog
In a recent Tax Court case, Tangel v. Commissioner, T.C. Memo. 2021-1 (Jan 2021), the Tax Court concluded that the taxpayer who claimed the R&D tax credit did not retain substantial rights and thus the R&D work was ‘funded’ and the R&D tax...
by Bruce Warner | Oct 10, 2014 | Blog
R&D Tax Credit Update 2014 – New Tax Court case on R&D credits rules favorably for taxpayer on almost all aspects of the case involving development of hardware and software. The taxpayer developed telephone equipment and related software and claimed the...
by Bruce Warner | Feb 10, 2014 | Blog
In the underlying TC Memo case Shami v. Commissioner, an R&D tax credit case, the Tax Court found that there was not sufficient evidence to show that two higher level managers were engaged in research activities for which the R&D credit was claimed based on...
by Bruce Warner | Oct 30, 2013 | Blog
In a new Section 199 Domestic Production Activities Deduction case, the Tax Court has ruled that a third party contract printer is entitled to the Section 199 deduction and not the publisher. ADVO, Inc. v. Commissioner, 141 T.C. 9 (2013). ADVO is a direct mail...
