Why read about the R&D tax credit on the web, when you can buy the book?
Dec 31st, 2002
Applied Systems, a Subchapter S corporation, develops and sells software that independent insurance agencies use to manage their businesses. During the early 1990s Applied Systems improved its software package, and its investors (the taxpayers in this case) want to take a tax credit under 26 U.S.C. § 41 based on the amount by which Applied [...]
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 [...]
Jan 14th, 2002
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 also [...]
Aug 27th, 2001
(a) Effective dates. (1) A corporation may claim a research and development credit, a jobs creation credit, or an investment credit only for expenses and payments that the corporation has incurred, qualified investments or expenditures that the corporation made, or new jobs that the corporation has created in Texas on or after January 1, [...]
Aug 14th, 2001
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 [...]
Mar 20th, 2001
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 [...]
(a) Alternative incremental credit. At the election of the taxpayer, the credit determined under section 41(a)(1) equals the amount determined under section 41(c)(4). (b) Election—(1) In general. A taxpayer may elect to apply the provisions of the alternative incremental credit in section 41(c)(4) for any taxable year of the taxpayer beginning after June 30, 1996. [...]
(a) New taxpayers. If, with respect to any credit year, the taxpayer has not been in existence for any previous taxable year, the average annual gross receipts of the taxpayer for the four taxable years preceding the credit year shall be zero. If, with respect to any credit year, the taxpayer has been in existence [...]
Jan 3rd, 2001
(a) Allocations—(1) Corporation making an election under subchapter S—(i) Pass-through, for taxable years beginning after December 31, 1982, in the case of an S corporation. In the case of an S corporation (as defined in section 1361) the amount of research credit computed for the corporation shall be allocated to the shareholders according to the [...]