Case Law

BACKGROUND Sun Microsystems Inc. (“Sun Microsystems”) v. Commissioner, T.C. Memo 1995-69 Sun Microsystems was a computer company that sold computers, computer components, software, [...]

BACKGROUND Deere & Co. v. Commissioner, 133 T.C. 11 (2009) Deere & Co manufactured and distributed agricultural equipment, commercial and consumer equipment, and a broad range of [...]

BACKGROUND Ekman v. Commissioner, 184 F.3d 522 (6th Cir. 1999) Leonard and Kaye Ekman, in their 1991 joint income tax return, claimed the cost of a Porsche engine that Leonard performed R&D [...]

BACKGROUND Wicor, Inc. (“Wicor”) v. United States, 263 F.3d 659 (7th Cir. 2001) Wisconsin gas company Wicor sought to integrate a computer system, so that it could perform a number of [...]

BACKGROUND United States v. Beltecno Inc. & Subs. (“Beltecno”), 104 AFTR 2d 2009-5929 (WD WA 2009) Cabinet manufacturer Beltecno filed amended tax returns in 2005 and 2006, and [...]

BACKGROUND Geosyntec Consultants, Inc. (“Geosyntec”) v. United States, 776 F.3d 1330 (11th Cir. 2015) Geosyntec is an engineering consultancy, specializing in environmental studies, [...]

BACKGROUND Suder v Commissioner T.C. Memo. 2014-201 In 1987, Eric Suder started Estech Systems, Inc (ESI), a tech company involved in developing telephone equipment and software. In 2004 to 2007 [...]

BACKGROUND CRA Holdings U.S., Inc (“CRA”) v. United States (No. 15-CV-239W(F)) (2019) Environmental engineering firm CRA claimed to have undertaken 6,100 research projects in 2002 and [...]

BACKGROUND Populous Holdings, Inc (“Populous”) v. Commissioner of Internal Revenue (Docket No. 405-17) (2019) Populous is an architecture firm, claimed R&D tax credit for [...]

BACKGROUND Quebe v U.S. (2019) Quebe Holdings, Inc (“QHI”) operates as three separate electrical companies: Chapel Electric, Romanoff Electric, and CRT Technologies. In 2013, QHI [...]