News: commissioner
Funded R&D – Rights – Tangel Case R&D Tax Credits
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 …
Tagged commissioner, contract, funded, funded R&D, funded research, IRS, R&D Tax Credit, research credit, Tangel, tax court
5th Circuit Largely Affirms Tax Court Decision in Shami v. Commissioner – R&D Credit Case
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 …
Tagged 5th circuit, commissioner, R&D credit, R&D Tax Credit, research credit, shami, tax court