Background – Case No. 8333-06. This is a case filed in the United States Tax Court.  The sole issue in this case is whether production molds TG Missouri Corporation sold to its customers [...]

Background Case no. 99-5039 This is an appeal in the U.S. Federal Court of Appeals where Lockheed Martin Corporation appeals the decisions made denying their attempt to introduce late filed [...]

Background This is an appeal from the U.S. Tax Court denying Union Carbide Corporation (UCC) a credit for supplies used in the conduct of qualified research.  Judge Pooler agrees with this [...]

Background In 1996, FedEx Corporation found a need for a new computer based system to more easily track their billing records. They carried out this project until 2001 when it was abandoned.  In [...]

Background United States (“The Government”) claims that Procter and Gamble (P&G) and its subsidiaries improperly excluded receipts from intercompany transfers with the foreign [...]

Background Apple Computer Incorporated treated incomes they earned from stock options as wages for increasing research activities in 1982, 1982 and 1983. Basic Facts The main question for this [...]

Background Trinity Industries v. United States (N.D. Tex. 2010) involves Trinity Industries seeking a refund for certain qualified research expenditures (QREs) tax credits claiming they were [...]

Background In 2009, the United States (“the Government”) filed an action to recover erroneously issued refunds to Morris and Cynthia Davenport and Myra Davenport for the 2003 tax year [...]

Background This case was filed on March 21, 2012 in the United States Tax Court.  The sole issue for decision in this case is whether or not certain wages from Farouk Systems, Inc. (FS) paid to [...]

Background This appeal took place in 2009 in the Fifth Circuit in the Southern District of Texas. The U.S. brought a suit against Arthur R. McFerrin seeking to recover a tax credit that the [...]