Cohan v Commissioner (1930)

Have more questions? Submit a request

Main Issue:

  • Documentation / Estimation


  • Taxpayer used estimates in place of actual amounts


  • Taxpayer may use estimates when he can show some factual foundation to make a reasonable estimate of the expense

Take-Away Point:

Companies do not need project tracking to qualify for the credit, however companies do need to have a credible basis for making any estimates. Companies are more likely to get court support in their estimates if it has proven that R&D activities are in existence and it is only the estimation of the amount of R&D at issue

Articles in this section

Was this article helpful?
0 out of 0 found this helpful
  • 8:00am - 8:00pm CST Monday to Friday; 9:00am - 6:00pm CST Saturday
  • Get the latest news and updates first



Please sign in to leave a comment.