When R&D Credit Claims Fail Before the IRS Reviews the Work
When R&D Credit Claims Fail Before the IRS Reviews the Work Many companies still believe R&D credit risk begins when the IRS evaluates whether the research qualifies. That assumption no longer holds. Today, many R&D credit claims fail earlier, at the filing stage, before the IRS ever examines technical eligibility. The exposure is procedural, not […]
The Harper Decision Clarifies R&D Credit Boundaries for Design-Build Firms
The Harper Decision Clarifies R&D Credit Boundaries for Design-Build Firms The Tax Court’s decision in Harper v. Commissioner is frequently cited as a win for construction and design-build firms pursuing the R&D tax credit. That reading is incomplete. Harper did not approve the claimed credits, expand eligibility, or relax substantiation standards. Instead, it rejected a […]
Dynetics Confirms Why Contract Terms Now Decide Most R&D Credit Claims
Dynetics Confirms Why Contract Terms Now Decide Most R&D Credit Claims The decision in Dynetics, Inc. v. United States is best understood as an early warning that contract language would come to dominate R&D tax credit eligibility. The case did not end ambiguity overnight, but it made clear that technical difficulty alone is insufficient when […]
The $3.26M Lesson: What the Little Sandy Coal Decision Means for R&D Tax Credits
The $3.26M Lesson: What the Little Sandy Coal Decision Means for R&D Tax Credits The federal ruling in Little Sandy Coal Company v. Commissioner is now one of the clearest indicators of how the IRS evaluates R&D tax credit claims. The case denied more than $3.26 million in credits for a shipbuilder that designed and […]
Why Contract-Based R&D Credit Claims Are Being Rejected Before the Work Is Reviewed
Why Contract-Based R&D Credit Claims Are Being Rejected Before the Work Is Reviewed Many engineering, architecture, and design firms still assume that technically complex contract work can qualify for the R&D tax credit. The assumption feels reasonable. If the work is customized, difficult, and performed by engineers, it should count. Recent court decisions make clear […]
What the Populous Holdings Case Means for R&D Tax Credits Under Client Contracts
What the Populous Holdings Case Means for R&D Tax Credits Under Client Contracts The Tax Court’s decision in Populous Holdings, Inc. v. Commissioner is one of the most important rulings on how contract research is evaluated under the R&D tax credit rules. In this case, the court rejected the IRS position that the taxpayer’s research […]
What the Suder v. Commissioner Decision Means for R&D Tax Credit Claims
What the Suder v. Commissioner Decision Means for R&D Tax Credit Claims The Tax Court decision in Suder v. Commissioner is one of the clearer examples of how a well-documented R&D tax credit claim can withstand IRS scrutiny. In this case, the court upheld most of the taxpayer’s claimed research projects, allowed a substantial portion […]
How TaxDrone.ai Protects You From “Betz-Style” R&D Credit Disallowances
How TaxDrone.ai Protects You From “Betz-Style” R&D Credit Disallowances The Tax Court case Betz v. Commissioner is a reminder that simply believing your work is “technical” isn’t enough to qualify for the R&D tax credit. In this case, Betz claimed credits for projects he thought counted as research. But when the IRS challenged the claim, […]
How TaxDrone.AI Protects You From “Trinity-Style” R&D Credit Denials
How TaxDrone.AI Protects You From “Trinity-Style” R&D Credit Denials The case Trinity Industries, Inc. v. United States shows how even large, sophisticated companies can lose out on the R&D tax credit if their claims don’t line up with IRS standards. Trinity, a major industrial manufacturer, claimed millions in R&D credits for engineering and design work. […]
How TaxDrone.AI Protects You From “Moore-Style” R&D Credit Denials
How TaxDrone.AI Protects You From “Moore-Style” R&D Credit Denials The Tax Court case Moore v. Commissioner is another example of how companies can lose valuable R&D credits—not because they weren’t innovative, but because they couldn’t prove it in the way the IRS requires. The Moores claimed credits for their business activities, but the IRS and […]