Siemer Milling Company v. Comm. (2019)

Have more questions? Submit a request

Main Issue:

  • Process of Experimentation


  • Taxpayer claimed the research credit for eight projects ranging from new products, process improvement, and machinery upgrades
  • The Court determined that none of the project qualified


  • Court found many of the projects failing multi-parts of the 4-part test.
  • Every project was found to fail the POE test
    • Reciting steps in a process does not explain how the process is scientific
    • Need a methodical plan involving a series of trials to test a hypothesis so that it constitutes an experimentation

Take-Away Point:

  • The taxpayer must demonstrate that there is a methodical process of experimentation and how it is used to test the hypothesis.
  • Court relied heavily on the UCC case.

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.