Introduction
Presented here is a suggested process for the conduct of the interviews of taxpayer employees or other knowledgeable individuals (interview subject) in connection with the examination of the Research Credit. Examiners should not that this is not a list of questions so much as a procedural framework for conducting the interview. It should [...]
The ‘R&D Tax Credit IRS Publications’ Category
Research Credit Interview Procedures
Rev. Rul. 85-186, 1985-2 C.B. 84
Research and experimental expenditures. Research or experimental costs previously deducted pursuant to section 174(a) of the Code are not subject to recapture upon the subsequent sale of the resulting technology. Rev. Rul. 72-528 revoked.
Rev. Rul. 85-186
ISSUE
Whether “tax benefit” recapture as ordinary income of research or experimental expenditures previously deducted pursuant to section [...]
Rev. Rul. 83-138, 1983-2 C.B. 50
Research or experimental expenditures; accounting methods change. A taxpayer may not change without the consent of the Commissioner its treatment of research or experimental expenditures from the deferred expense method to the expense method of accounting by filing an amended federal income tax return.
Rev. Rul. 83-138
ISSUE
May a taxpayer change its treatment of [...]
Rev. Rul. 80-245, 1980-2 C.B. 72
Research and experimental expenses; environmental impact studies. A public utility company conducted, and paid another organization to conduct, environmental impact studies to support its application to state regulatory agencies to expand its generating facilities. The expenses are not research and experimental expenditures within the meaning of section 174 of the Code. However, if not chargeable [...]


