In Union Carbide Corporation and Subsidiaries v. Commissioner, T.C. Memo. 2009-50 (2009), the U.S. Tax Court examined the taxpayer’s research tax credits. The taxpayer determined its research tax credits to be $18 million. The IRS conceded these amounts in a negotiated settlement; however, the taxpayer believed it was entitled to an additional $8 million in [...]
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Respondent determined deficiencies in petitioner’s Federal income tax of $20,481,520 and $140,732,254 for 1994 and 1995, respectively. In its petition, as amended, petitioner alleges that it is entitled to additional research credits under section 41 [1] of approximately $3,656,091 and $4,726,664 for 1994 and 1995, respectively (claimed credits). [2] The claimed credits are based on [...]
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