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 the R&D tax...
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 credit was claimed based on...