Industry Case Studies: Applied R&D Tax Credit Eligibility in Johns Creek

The economic landscape of Johns Creek is characterized by a deliberate concentration of high-technology, life sciences, and advanced manufacturing enterprises. The following five case studies dissect the specific research activities conducted within these localized industries, articulating why these sectors took root in Johns Creek and detailing their eligibility under federal Internal Revenue Code (IRC) Section 41 and the Official Code of Georgia Annotated (O.C.G.A.) § 48-7-40.12.

Case Study 1: Medical Device and Vision Care Manufacturing

The medical device and vision care sector represents the most prominent industrial cluster within Johns Creek. The city serves as a global hub for Alcon, the world’s largest eye care device company, which operates a massive manufacturing and research facility within the municipality. Furthermore, Boston Scientific recently established a $62.5 million state-of-the-art manufacturing and pathology laboratory on Johns Creek Parkway. The development of this specific industry in Johns Creek is the result of the city’s strategic proximity to the biomedical engineering talent cultivated at the Georgia Institute of Technology and the clinical research networks of Emory University. Additionally, local municipal zoning specifically accommodated the specialized infrastructure required for clean-room manufacturing and continuous fluid dynamics testing, allowing these corporations to seamlessly transition from academic prototype development to mass commercialization.

To qualify for the federal R&D tax credit, the engineering activities conducted by these medical device manufacturers must satisfy the strict Four-Part Test mandated by IRC Section 41(d). For vision care manufacturers developing products like the DAILIES TOTAL1® or PRECISION1® contact lenses, the permitted purpose relates to improving oxygen transmissibility, surface lubricity, and visual acuity for patients suffering from astigmatism or presbyopia. This research is inherently technological in nature, relying heavily on advanced polymer chemistry, materials science, and optical physics.

The critical threshold for these manufacturers lies in the elimination of uncertainty and the process of experimentation. When engineers attempt to design flexible manufacturing platforms capable of producing modular, interchangeable contact lenses, they face objective uncertainties regarding thermal stress, biometric compatibility, and structural integrity during high-speed production. To resolve these uncertainties, researchers execute a systematic process of experimentation involving iterative clinical prototype runs, destructive testing, and analytical modeling of fluid dynamics within the surgical cavity.

From a compliance perspective, these manufacturers must carefully navigate federal case law regarding pilot models. As established in the United States Tax Court order for Intermountain Electronics, Inc., taxpayers face intense scrutiny when attempting to claim the production costs of physical prototypes. Medical device manufacturers in Johns Creek must maintain highly granular, contemporaneous documentation to prove that the production of trial contact lenses or endoscopy tools was explicitly for testing and validation purposes in the experimental sense, rather than routine pre-commercial inventory stockpiling.

Under Georgia law, the expenditures related to these local activities generate substantial state-level tax benefits. O.C.G.A. § 48-7-40.12 explicitly recognizes manufacturing and research and development industries as eligible business enterprises. Because the wages paid to the process engineers and the materials consumed during the prototype runs occur physically within the Johns Creek facilities, these costs qualify for the 10% Georgia incremental credit. By properly identifying these qualified research expenses (QREs), multinational device manufacturers effectively neutralize up to 50% of their corporate net income tax liabilities within the state of Georgia, providing a critical financial advantage that incentivizes further facility expansion.

Case Study 2: Logistics and Supply Chain Technology

The logistics industry in Johns Creek is anchored by Saia, Inc., a premier Less-Than-Truckload (LTL) logistics carrier that generates nearly $3 billion in annual revenue. Saia relocated its corporate headquarters to the Johns Creek Technology Park in 1996. The rationale for this strategic relocation was multifaceted: the company required a geographic location that offered immediate access to Metro Atlanta’s massive interstate freight corridors while simultaneously providing a corporate campus environment capable of attracting elite software engineering talent. As the transportation industry underwent rapid digital transformation, Saia transitioned from a traditional asset-heavy trucking firm into a technology-driven logistics enterprise, investing heavily in predictive analytics, dynamic routing algorithms, and supply chain automation.

The R&D tax credit eligibility for logistics technology hinges on the complex federal regulations governing software development. Saia’s creation of proprietary systems, such as the RouteMAX optimization algorithm and AI-driven predictive capacity platforms, is designed to overcome technical uncertainties regarding real-time traffic pattern integration, fluctuating freight density matrices, and legacy system interoperability. These initiatives clearly rely on the principles of computer science and data architecture, thereby meeting the technological in nature requirement. The process of experimentation manifests through agile software development cycles, beta-testing predictive models against historical transit data, and iterative code refactoring to resolve latency within the application programming interfaces (APIs).

However, because logistics firms typically develop this software to optimize their own internal freight networks rather than selling the software commercially, the IRS classifies these projects as Internal Use Software (IUS). IUS is presumptively excluded from the federal R&D tax credit under IRC Section 41(d)(4)(E) unless the taxpayer can demonstrate that the software satisfies the stringent High Threshold of Innovation (HTI) test.

To survive an IRS audit, logistics developers in Johns Creek must produce technical documentation proving three additional elements beyond the standard Four-Part Test. First, the software must be highly innovative, resulting in a reduction in cost or improvement in speed that is substantial and economically significant. Second, the development must involve significant economic risk, meaning the taxpayer commits substantial resources with a high level of objective uncertainty regarding whether the software will ultimately function as intended. Third, the software must not be commercially available for use without significant custom modification. By meticulously documenting the architectural failures and algorithmic complexities encountered during the development of their proprietary routing networks, Johns Creek logistics firms can successfully capture federal R&D credits for the wages of their Chief Information Officers, data scientists, and systems architects. At the state level, these software development wages are fully apportionable to the Johns Creek headquarters, allowing the firm to leverage the Georgia R&D credit to offset state corporate tax burdens while reinvesting the saved capital back into local technology infrastructure.

Case Study 3: Precision Industrial Manufacturing Equipment

Precision industrial manufacturing represents a highly specialized sector within the Johns Creek economy, predominantly driven by Nordson Corporation. As a multinational manufacturer of precision dispensing equipment, Nordson operates significant divisions—including its Adhesive Dispensing Systems and Engineering groups—out of the Johns Creek and broader North Fulton area. The historical development of this sector in Johns Creek traces back to the late 1980s, when the Technology Park was explicitly zoned to accommodate light industrial testing and corporate engineering offices in a unified suburban campus. This allowed firms like Nordson to physically merge their executive leadership with their applied research laboratories, drawing on the steady influx of mechanical and fluid dynamics engineers graduating from regional technical colleges and universities.

The research activities conducted within this sector are quintessential examples of applied hard sciences. When industrial manufacturers develop new automated hot melt glue dispensing robots, high-volume jetting valves, or polymer processing equipment, they are engaging in the design of new business components intended for commercial sale. The technical uncertainty in this field is severe; engineers must determine how to prevent thermal degradation of adhesives at high application speeds, how to maintain microscopic fluid deposit accuracy under volatile factory conditions, and how to eliminate clogging in two-component (2K) mixing modules. To eliminate this uncertainty, the engineering teams utilize Computer-Aided Design (CAD) for structural simulation, build multiple iterations of physical valves, and conduct extensive thermodynamic stress testing, which squarely satisfies the IRS requirement for a process of experimentation.

A unique legal challenge for custom industrial equipment manufacturers is the application of the “Funded Research” exclusion under IRC Section 41(d)(4)(H). Often, precision manufacturers develop highly customized equipment specifically tailored to the unique assembly line parameters of a single client. The IRS strictly scrutinizes these arrangements. As demonstrated in the 2024 Eighth Circuit Court of Appeals decision in Meyer, Borgman & Johnson, Inc. v. Commissioner, if a client pays the manufacturer on a time-and-materials basis, or if the contract does not explicitly make payment contingent upon the ultimate success of the technical research, the IRS will deem the research to be funded by the client, entirely disqualifying the manufacturer from claiming the credit.

To secure federal and state R&D tax credits, manufacturers in Johns Creek must carefully construct their commercial agreements as fixed-price contracts, thereby retaining the financial risk of technical failure. Furthermore, the manufacturer must retain substantial rights to the intellectual property and engineering schematics generated during the project. By aligning their contractual risk with their physical experimentation in the Johns Creek laboratories, industrial manufacturers can legitimately claim the wages of their mechanical engineers, the cost of raw materials consumed during valve testing, and external contractor fees as QREs under both the federal statute and O.C.G.A. § 48-7-40.12.

Case Study 4: Healthcare IT and Clinical Decision Support

The integration of software technology with clinical healthcare has spawned a massive secondary industry in Johns Creek. Anchored by the 1,250-employee Emory Johns Creek Hospital, the city has cultivated an ecosystem comprising over 450 healthcare and social service companies. The municipal government actively catalyzed this development by branding Johns Creek as a premier hub for health, wellness, and innovation, ultimately becoming the first municipality in Georgia to receive the “BioReady” community designation. This designation signaled to biotechnology and healthcare IT startups that the city had streamlined its zoning, permitting, and infrastructure protocols specifically to accommodate clinical research and digital health operations.

The primary R&D focus within this cluster involves the development of Clinical Decision Support (CDS) software, telemedicine platforms, and the integration of electronic health records (EHR) with biometric data. The technical uncertainties inherent in this field are profound. Software developers must determine how to engineer interoperable APIs that allow disparate medical devices to communicate seamlessly, how to process massive sets of anonymized clinical data using machine learning algorithms to improve diagnostic accuracy, and how to construct database architectures that comply with stringent FDA and HIPAA cybersecurity mandates. The process of experimentation involves writing custom code, stress-testing server loads, and evaluating alternative cryptographic frameworks to protect patient data.

Under federal law, the wages paid to software engineers, data scientists, and bioinformatics specialists constitute the bulk of the QREs in this sector. However, startups face significant compliance hurdles regarding the substantiation of executive time. As illustrated in the Tax Court case Moore v. Commissioner (2023), the IRS frequently disallows the wages of high-level executives (such as Chief Operating Officers) if the taxpayer relies solely on generic payroll records. Healthcare IT firms in Johns Creek must implement rigorous, contemporaneous time-tracking software to explicitly prove the exact percentage of time their executives spend directly supervising or directly supporting qualified coding activities, linking those hours to specific business components.

For early-stage, pre-revenue healthcare IT startups operating in Johns Creek, the Georgia state R&D tax credit provides a transformative liquidity mechanism. While federal credits are generally applied against income tax liability, the Georgia Department of Revenue permits businesses to monetize excess R&D credits by applying them against state payroll withholding obligations. A clinical software startup that is actively burning capital on development and has no state income tax liability can file Form IT-WH (Notice of Intent) with the state. Upon receiving a Letter of Eligibility from the Department of Revenue, the startup can effectively keep the state income taxes withheld from its employees’ paychecks, generating immediate, non-dilutive cash flow to fund further innovation.

Case Study 5: Financial and Insurance Technology (InsurTech)

The Financial and Insurance Technology (InsurTech) sector in Johns Creek highlights the city’s capacity to host large-scale corporate consolidation. Ebix, Inc., a multinational provider of on-demand software and e-commerce services to the insurance industry, relocated its global headquarters to a 17.6-acre campus in the Johns Creek Technology Park in 2015. By acquiring and renovating 100,000 square feet of office space, Ebix consolidated multiple disparate regional offices into a singular, cohesive technology campus. This migration was driven by the availability of highly skilled computer science professionals residing in the affluent northern suburbs of Metro Atlanta, combined with the city’s robust fiber-optic infrastructure required to support global data exchanges.

Ebix’s research and development activities revolve around the continuous modernization of cloud computing Software-as-a-Service (SaaS) platforms, carrier systems, and digital payment architectures. With platforms processing billions of dollars in annual policy premiums and facilitating millions of compliance images, the technological demands are staggering. Software architects face objective technical uncertainty regarding how to scale cloud databases to handle massive, concurrent global transaction loads without latency, and how to engineer secure, cryptographic payment gateways that interoperate with decades-old legacy mainframe systems utilized by traditional insurance carriers. The experimentation process involves designing and testing new algorithms, executing latency benchmarking, and deploying iterative code variations within sandbox environments prior to commercial release.

Crucially, because InsurTech platforms developed by firms like Ebix are expressly designed to be licensed, leased, or sold to third-party brokers and carriers, they avoid the restrictive Internal Use Software (IUS) classification. This classification significantly lowers the regulatory burden, as the software is not subjected to the High Threshold of Innovation test.

However, large-scale software developers face severe scrutiny under the Business Component test. As demonstrated in the Fifth Circuit Court of Appeals ruling in Grigsby v. Commissioner, taxpayers cannot claim the R&D credit based on vague, overarching project descriptions. InsurTech firms in Johns Creek must meticulously delineate their development efforts, defining exact, discrete software modules, API endpoints, or database structures as individual business components. Furthermore, the introduction of Section G on the IRS Form 6765 mandates that these firms report quantitative expenditure data and qualitative descriptions for up to 50 individual business components in descending order of cost. At the state level, because O.C.G.A. § 48-7-40.12 explicitly includes telecommunications and processing industries, the data-centric software development conducted at the Johns Creek campus generates vast QREs, permitting the corporation to heavily offset its Georgia net income tax liability.

The Evolution of Johns Creek as an Innovation Hub

The ability of Johns Creek to sustain these five diverse, R&D-intensive industries is inextricably linked to its unique historical and economic development. Prior to the late 20th century, the region was primarily rural, characterized by the descendants of 19th-century pioneer farming families. The paradigm shift occurred through the deliberate vision of academic and corporate planners.

In the 1960s, Paul Duke, a graduate of the Georgia Institute of Technology, identified a critical vulnerability in Georgia’s economy: the state’s universities were producing world-class engineers, but these graduates were immediately migrating to established tech hubs in California or the Northeast due to a lack of local employment opportunities. Drawing inspiration from the Research Triangle in North Carolina, Duke conceptualized a dedicated technological ecosystem, successfully launching Technology Park Atlanta in neighboring Peachtree Corners. The project was a massive success, attracting early anchor tenants like Scientific Atlanta and serving as the birthplace of the Hayes PC modem.

Seeking to replicate and expand upon this success, developers in 1981 acquired 1,800 acres of agrarian land further north, officially naming the mixed-use community “Technology Park/Johns Creek”. This development represented the first geographic codification of the Johns Creek identity. The master plan was meticulously designed to foster innovation, integrating over six million square feet of low- and mid-rise research and office buildings with upscale residential subdivisions and recreational amenities. By creating a “live-work-play” environment, the park allowed corporations to recruit highly paid scientific professionals who desired minimal commute times and premium suburban living.

The economic gravity of Technology Park ultimately led to the formal municipal incorporation of the City of Johns Creek in 2006. Today, the city relies upon this foundational infrastructure to drive its economic development strategy. The municipal government continually invests in advanced utilities, notably expanding commercial fiber-optic networks to guarantee the high-speed data transmission required by modern software and biomedical enterprises. Demographically, the strategy has resulted in an affluent, highly educated population; the city reports a median household income exceeding $153,000, with “Professional, Scientific, and Technical Services” functioning as the largest employment sector. This concentration of intellectual capital and purpose-built infrastructure ensures that companies locating in Johns Creek are uniquely positioned to maximize the financial advantages of both federal and state R&D tax incentives.

The United States Federal R&D Tax Credit Framework and Legal Analysis

The federal R&D tax credit, originally enacted to prevent the offshoring of American technological development, functions as one of the most complex and heavily litigated provisions within the Internal Revenue Code. Understanding the intersection of IRC Section 41, IRC Section 174, and the rigorous evidentiary standards established by recent tax court rulings is paramount for Johns Creek enterprises.

The Statutory Mechanisms of Section 41

Under IRC Section 41, taxpayers are entitled to a tax credit generally equal to 20% of their Qualified Research Expenses (QREs) that exceed a historically derived base amount. The foundation of this calculation relies upon the precise definition of QREs, which are strictly limited to three categories of expenditures incurred in the performance of qualified research:

• Wages: Direct compensation paid to employees for physically conducting research, directly supervising research, or directly supporting the research process (e.g., a machinist building a prototype).
• Supplies: The cost of tangible property consumed, destroyed, or fundamentally altered during the experimentation process. This specifically excludes land, depreciable assets, and general administrative overhead.
• Contract Research: 65% of the fees paid to third-party consultants or specialized testing laboratories, provided the taxpayer retains the financial risk of the research and the rights to the intellectual property.

To classify these expenditures as QREs, the underlying activities must survive the rigorous Four-Part Test mandated by Section 41(d), applied sequentially to each discrete business component.

If a large-scale project fails the Four-Part Test at the macro level, IRS regulations invoke the “Shrink-Back Rule.” This legal mechanism requires the examiner to apply the test to the most significant subset of elements within the project, continuously shrinking the scope until a qualifying sub-component is identified or the most basic element fails. Furthermore, Section 41(d)(4) codifies strict statutory exclusions. Research conducted after commercial production has commenced—such as routine debugging, quality control testing, or reverse engineering—is explicitly excluded, as the technical uncertainty is deemed to have already been resolved. Similarly, any research conducted outside the physical borders of the United States is disqualified, requiring multinational firms in Johns Creek to carefully apportion their global R&D budgets.

The Intersection of Section 41 and Section 174 Amortization

The financial utility of the R&D credit is heavily influenced by the accounting treatment of the underlying expenses under IRC Section 174. Historically, taxpayers were permitted to immediately deduct R&E expenditures under Section 174 in the year they were incurred while simultaneously claiming the Section 41 tax credit.

However, mandatory capitalization rules instituted by the Tax Cuts and Jobs Act (TCJA) fundamentally altered this landscape. For taxable years beginning after December 31, 2021, taxpayers were forced to capitalize domestic R&E expenses and amortize them over a five-year period (or fifteen years for foreign research), severely impacting the immediate cash flow generated by innovation.

In a massive legislative shift, the recent passage of the “One Big Beautiful Bill Act” (OBBBA) in 2025 introduced Section 174A, restoring the ability of taxpayers to immediately expense domestic R&E costs. Under the complex transition rules dictated by the IRS and Rev. Proc. 2025-28, eligible taxpayers can now deduct unamortized balances from the 2022-2024 period entirely in 2025, or elect to spread the deduction ratably across 2025 and 2026. Small businesses are granted a further election to retroactively amend their prior-year returns to claim immediate deductions, fundamentally restructuring corporate tax planning for research entities.

Heightened Regulatory Scrutiny and Case Law Precedents

The IRS has aggressively escalated its enforcement of the Four-Part Test, supported by a string of recent federal court decisions that drastically raise the evidentiary burden for corporate taxpayers.

In the 2024 Tax Court decision Phoenix Design Group, Inc. v. Commissioner, a mechanical and electrical engineering firm was denied all R&D credits and subjected to a 20% accuracy-related penalty. The court ruled that the taxpayer completely failed the “Process of Experimentation” test because they relied on post-hoc, generalized descriptions of engineering challenges. The critical takeaway for Johns Creek engineering firms is that the IRS now demands contemporaneous, project-level documentation that explicitly identifies the specific technological uncertainty at the outset of the project, followed by documented evidence of the scientific alternatives tested.

Similarly, the Fifth Circuit’s ruling in Grigsby v. Commissioner emphasized the strict interpretation of the “Business Component” test. The court disallowed the credit because the taxpayer attempted to claim macro-level projects without clearly defining the discrete products or processes being developed. This legal precedent is directly reflected in the IRS’s 2025 overhaul of Form 6765. The newly implemented Section G reporting requirements mandate that taxpayers provide detailed, quantitative cost breakdowns and qualitative functional descriptions for individual business components, effectively ending the era of high-level statistical estimations.

The Georgia State R&D Tax Credit Framework and Administrative Rulings

Working in tandem with the federal statute, the State of Georgia offers a highly lucrative, localized R&D tax credit designed to stimulate domestic investment. Codified in O.C.G.A. § 48-7-40.12, the credit heavily incentivizes businesses to concentrate their high-paying scientific and engineering jobs within state lines.

State Statutory Requirements and the Base Amount

To establish eligibility for the Georgia Research Tax Credit, a business enterprise must first successfully claim and be allowed the federal research credit under IRC Section 41 for the concurrent taxable year. The state statute imposes strict geographic limitations; only wages paid and supplies consumed for research physically conducted within the State of Georgia qualify for the calculation. This requires multinational corporations in Johns Creek to rigorously apportion their federal QREs to isolate the Georgia-specific spend. Furthermore, eligibility is restricted to specific commercial sectors, explicitly including manufacturing, telecommunications, broadcasting, software development, and dedicated research and development industries, while explicitly excluding retail operations.

The financial architecture of the Georgia credit is incremental, rewarding companies solely for increasing their R&D spend relative to historical performance. The credit is calculated as 10% of the current year’s Georgia QREs that exceed a statutorily defined “base amount”. According to Georgia Department of Revenue Regulation 560-7-8-.42, the base amount is mathematically determined by multiplying the business’s current year Georgia gross receipts by the lesser of two figures:

1. A fixed cap of 30 percent (0.300).
2. The taxpayer’s historical R&D intensity, calculated as the average ratio of aggregate Georgia QREs to Georgia gross receipts over the preceding three taxable years.

If a newly formed technology startup in Johns Creek possesses no Georgia gross receipts in any of the preceding three years, the statute dictates that the base amount is calculated using the 30% fixed multiplier against current year receipts.

Legal Interpretations and Appellate Case Law

The precise calculation of the Georgia base amount was the subject of intense litigation in the landmark appellate case Georgia Department of Revenue v. Georgia Chemistry Council, Inc. (2004).

The Georgia Chemistry Council, representing biotech startups, initiated a declaratory judgment action to invalidate a Department of Revenue regulation that required a business to possess positive Georgia taxable net income in the prior three years to compute the historical base ratio. The Council argued this administrative interpretation was ultra vires and unfairly penalized pre-revenue startups that naturally operated at a net operating loss during their initial research phases.

The Georgia Court of Appeals reversed the lower court and upheld the Department of Revenue’s regulation. Applying the rules of statutory construction, the appellate court noted that the legislature explicitly used the term “taxable net income” and deliberately omitted the term “net operating loss”. Utilizing the legal doctrine of expressio unius est exclusio alterius, the court determined the legislature intended the figure to be a positive integer. Furthermore, the court deferred to executive agency expertise, noting that if negative income were injected into the statutory ratio, comparing the result against the positive 30% threshold would render the mathematical formula legally meaningless. (Note: The Georgia General Assembly subsequently amended O.C.G.A. § 48-7-40.12 to replace “taxable net income” with “Georgia gross receipts” in the base calculation, establishing the modern framework and mitigating the penalty on pre-profit startups).

Utilization, Carryforwards, and the Payroll Withholding Offset

Once the 10% incremental credit is calculated, the State of Georgia provides robust, yet capped, mechanisms for utilization. The generated credit can be used to offset up to 50% of the corporation’s remaining Georgia net income tax liability for the year, applied after all other tax credits have been exhausted.

Historically, any unused credit could be carried forward for 10 years. However, businesses must account for recent legislative tightening: credits generated in taxable years beginning on or after January 1, 2025, are now restricted to a shortened five-year carryforward period.

The most powerful mechanism of the Georgia R&D framework is the payroll withholding election. If the generated credit exceeds the 50% income tax liability cap—a frequent occurrence for highly capitalized, pre-profit software and biotech startups in Johns Creek—the enterprise can elect to apply the excess credit directly against its state payroll withholding tax obligations.

To execute this monetization, the taxpayer must file Form IT-RD with their corporate return and subsequently file Form IT-WH (Notice of Intent) electronically via the Georgia Tax Center. Crucially, taxpayers now operate under an expanded 3-year statutory window to make this irrevocable election, a significant improvement over previous 30-day deadlines. Upon an administrative review spanning up to 120 days, the Department of Revenue issues a Letter of Eligibility, allowing the startup to retain the cash normally remitted to the state for employee tax withholdings, thereby injecting non-dilutive capital directly back into local research operations.

Final Thoughts

The intersection of the United States federal R&D tax credit and the State of Georgia’s research incentives provides a profoundly powerful financial catalyst for continuous technological innovation. By meticulously defining qualified research expenses under the rigorous Four-Part Test of IRC Section 41, and capitalizing on Georgia’s 10% incremental credit and payroll withholding monetization provisions, businesses can dramatically reduce their effective tax rates and enhance their operational cash flow.

The City of Johns Creek, anchored by the historical legacy of the Technology Park, its strategic fiber-optic infrastructure, and its dense concentration of specialized intellectual capital, functions as an ideal incubator for this economic dynamic. From the advanced fluid dynamics engineering at Nordson and the proprietary polymer chemistry at Alcon, to the complex algorithmic architectures developed by Saia and Ebix, the industries anchoring Johns Creek are prime candidates for maximizing state and federal tax strategies. However, as evidenced by aggressive IRS enforcement trends and appellate court rulings, success in this highly lucrative regulatory environment remains entirely dependent upon proactive, project-level accounting and flawless contemporaneous legal documentation.

The information in this study is current as of the date of publication, and is provided for information purposes only. Although we do our absolute best in our attempts to avoid errors, we cannot guarantee that errors are not present in this study. Please contact a Swanson Reed member of staff, or seek independent legal advice to further understand how this information applies to your circumstances.