Research Tax Credit

Plaintiff taxpayers filed a refund suit seeking money allegedly owed them from a tax credit for research and development expenses under I.R.C. § 41. In a matter of first impression in this circuit, we interpret the scope of “qualified research” under I.R.C. § 41, including the requirement in § 41(d)(1) that the taxpayer must intend [...]

An affiliated group of corporations that file a joint federal income tax return brought this suit on behalf of one of the affiliates, the Wisconsin Gas Company, a retail distributor of natural gas, for refund of federal income taxes. The plaintiff argues that the gas company was incorrectly denied a tax credit under section 41 [...]

By notices dated July 2, 1996, respondent determined deficiencies and additions to petitioners’ Federal income taxes as follows: Nicholas Eustace, docket No. 21088-96 Year Deficiency 1992 $3,239 Estate of Thomas A. Eustace, Deceased, Vicky Eustace, Executor, docket Nos. 21149-96 and 21177-96 Year Deficiency Sec. 6662(a) Addition 1990 $71,505 $14,301 1991 588 – Estate of Thomas [...]

Lockheed Martin Corporation appeals from the decisions of the United States Court of Federal Claims (1) denying Lockheed Martin’s attempt to introduce late-filed expenses in its tax refund suit, see Lockheed Martin Corp. v. United States, 39 Fed. Cl. 197 (1997), and (2) granting the government’s motion for summary judgment that Lockheed Martin was not [...]