Alex
Articles
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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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Union Carbide v. Commissioner (2012)
Main Issue: Uncertainty Base period Facts: Taxpayer is manufacturer of chemicals and plastics Claimed credits for 106 projects of which 5 were selected as the sample for this case IRS argued not...
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Basim Shami and Rania Ardah v. Commissioner (2014)
Main Issue: Above first-line management qualification of time Oral testimony Facts: Company was confirmed to have been performing R&D prior to litigation President and Executive Vice-President w...
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United States v. McFerrin (2009)
Main Issue: Substantiation / Oral testimony Facts: District Court determined there were no records of the hours worked on any given project or supplies used that involved research District Court...
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Trinity Industries v. United States (2014)
Main Issue: Supplies expense “Substantially all” rule Facts: Credits claimed for development of special order ships Claimed all expenses associated with the construction and development of first...
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TG Missouri v. Commissioner (2009)
Main Issue: Supplies expense Facts: Taxpayer designs and engineers production molds which are then sold to their customers Taxpayer maintains possession of the molds Taxpayer included the costs ...
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Bayer v. United States (2012)
Main Issue: Statistical sampling / Documentation Facts: Taxpayer took cost center approach to qualification refusing to identify each business component so that a statistical sampling approach c...
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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...
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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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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...