P develops and uses production molds to manufacture automotive parts for its customers. P contracts with third-party toolmakers to build the production molds that P does not construct. After a third-party toolmaker finishes constructing a production mold, P purchases the mold and incurs additional design and engineering costs to modify the mold so that it [...]

The United States brought suit against Arthur R. McFerrin (”McFerrin”[1] ) seeking to recover a tax credit that the government alleges was erroneously paid by the Internal Revenue Service (”IRS”) to McFerrin. After a six day bench trial, the district court held that the government had proved by a preponderance of the evidence that the [...]

ORDER GRANTING PLAINTIFF’S MOTION FOR PARTIAL SUMMARY JUDGMENT Before the Court is Plaintiff FedEx Corporation’s (“FedEx”) February 11, 2009 motion for partial summary judgment on the legal standards governing certain research tax credits FedEx claims under 26 U.S.C. § 41. More specifically, FedEx seeks summary judgment on the legal standard for the “discovery” test under [...]

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 [...]