Alex
Activity overview
Latest activity by Alex-
Alex created an article, Employee Retention Credit (ERC)
The Employee Retention Credit (ERC) allows taxpayers to generate a tax credit based on wages paid during COVID-related government shut down periods in addition to periods of financial distress (low...
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Alex created an article, Siemer Milling Company v. Comm. (2019)
Main Issue: Process of Experimentation Facts: Taxpayer claimed the research credit for eight projects ranging from new products, process improvement, and machinery upgrades The Court determined ...
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Alex created an article, Dynetics Inc. and Subsidiaries v. United States (2015)
Main Issue: Funded Research Facts: Taxpayer claimed the research credit for client projects related to developing unmanned systems used in national security Taxpayer claimed research expenses as...
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Alex created an article, Geosyntec Consultants, Inc. v. United States (2015)
Main Issue: Funded Research Facts: Taxpayer claimed the research credit for client projects related to environmental and geological infrastructure consulting and engineering Taxpayer claimed res...
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Alex created an article, United States v. Davenport (2012)
Main Issue: Internal Use Software / Process of Experimentation Facts: Taxpayer claimed the research credit for the implementation and customization of an ERP system IRS argued that the research ...
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Alex created an article, Suder v. Commissioner (2014)
Owner who made $10 million per year and was qualified at 75% each year Credible testimony presented related to his activities “Reasonable” standard = paid under like circumstances for like activit...
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Alex created an article, Fairchild v. United States (1995)
Main Issue: Funded research – economic risk Facts: Taxpayer included QRAs associated with fixed price contracts IRS argued that taxpayer did not have economic risk Conclusion: Court rejected t...
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Alex created an article, Lockheed Martin v. United States (2000)
Main Issue: Funded research - rights Facts: Taxpayer included fixed price contracts in which they did not have exclusive rights to what was developed IRS argued that taxpayer did not have substa...
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Alex created an article, Deere & Co. v. Commissioner (2009)
Main Issue: Foreign Gross Receipts Facts: Taxpayer excluded gross receipts from foreign branches IRS argued that foreign gross receipts were to be included Conclusion: Court rejected the taxpa...
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Alex created an article, Procter & Gamble v. United States (2010)
Main Issue: Intercompany Transactions / Gross Receipts Facts: Taxpayer excluded intercompany gross receipts including transactions with foreign members IRS argued that only QREs, not gross recei...