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 …

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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 …

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