Industry Case Studies and Historical Development in Livonia, Michigan

To accurately assess the eligibility of local enterprises for research and development tax credits, it is critical to understand the industrial ecosystem in which these companies operate. Livonia, Michigan, located approximately 20 miles northwest of downtown Detroit in Wayne County, presents a unique economic geography. Originally organized as Livonia Township in 1835, the area spent its first century as a rural agricultural community. Pioneers drawn to the rich soil established prosperous dairy farms, fruit orchards, and sheep pastures, eventually earning the township the historical moniker of the “cheese capital” of Michigan.

However, the post-World War II boom catalyzed a dramatic transformation. In 1948, the General Motors Corporation constructed a massive, state-of-the-art automatic transmission plant in the township, followed swiftly by a Ford Motor Company parts depot. To manage this explosive growth and capture corporate tax revenues, the residents voted to incorporate the City of Livonia in 1950. Following the catastrophic destruction of the GM plant during the Great Hydra-Matic Fire of 1953—the worst industrial fire in American history, which prompted a nationwide overhaul of industrial fire codes—Livonia rebuilt its manufacturing sector with profound resilience. Today, a dense six-square-mile industrial corridor runs through the city, flanked by the I-96 (Jeffries) Expressway and the I-275 Expressway, facilitating complex supply chains and advanced manufacturing operations.

The following case studies illustrate how specific industries evolved from this historical foundation and how their modern operations align with the stringent requirements of federal and state R&D tax credit laws.

Case Study: Automotive and Mobility Engineering

Historical Development in Livonia: Livonia’s modern identity is inextricably linked to the automotive industry. Following the establishment of the GM and Ford facilities in the late 1940s, the city became a critical node for Tier 1, Tier 2, and aftermarket automotive suppliers. This density of manufacturing infrastructure attracted highly skilled engineering talent. In 1976, Jack Roush, a former Ford quality control engineer, founded Jack Roush Performance Engineering. Initially supplying racing engines, Roush Enterprises expanded exponentially into a global provider of automotive engineering, testing, product development, and prototype services, eventually employing thousands at its Livonia headquarters. As the industry pivoted toward the 21st century, the facilities in Livonia, including the Plymouth Road Technical Center (redeveloped from a former GM Trim Plant), transformed to focus on electric vehicles (EVs), autonomous mobility, and advanced powertrain design.

Example of Qualifying Activity: An automotive engineering firm headquartered in Livonia is contracted by an Original Equipment Manufacturer (OEM) to design a novel thermal management system for a high-performance EV battery pack. The engineers are constrained by a strict spatial envelope within the vehicle’s chassis and must achieve unprecedented heat dissipation metrics to prevent thermal runaway. The firm develops multiple Computer-Aided Design (CAD) iterations, runs complex Computational Fluid Dynamics (CFD) simulations, and constructs physical prototype cooling plates for destructive thermal testing.

Detailed Analysis of Tax Credit Eligibility:

• Federal Law and Guidance: This project strongly aligns with the Internal Revenue Code (IRC) Section 41 four-part test. The wages paid to the engineers qualify under IRC Section 174 as experimental costs. The activity relies on the hard sciences of mechanical engineering and thermodynamics, satisfying the technological in nature requirement. The thermal management system serves as the new business component. Finally, the iterative use of CFD simulations and physical prototyping to resolve the thermal dissipation uncertainties constitutes a clear process of experimentation.
• Case Law Implications: The firm must carefully navigate the “Funded Research” exclusion detailed in Meyer, Borgman & Johnson, Inc. v. Commissioner (2024). If the OEM contract is structured as “time and materials” or guarantees payment regardless of whether the thermal system functions correctly, the IRS will deem the research funded and ineligible. The Livonia firm must ensure the contract is “firm-fixed-price,” thereby absorbing the financial risk of failure, and must retain shared intellectual property rights to the design methodology. Furthermore, citing the precedent in Little Sandy Coal Co. v. Commissioner (2023), the firm must maintain rigorous, contemporaneous time-tracking data to prove that “substantially all” (80% or more) of the claimed engineering hours were spent directly on experimentation, rather than administrative overhead.
• Michigan State Law (PA 186/187): Under the newly reinstated Michigan R&D tax credit, effective January 1, 2025, the wages of the engineers physically working in the Livonia facility qualify as Michigan Qualified Research Expenses (MQREs). If the engineering firm employs more than 250 personnel, it classifies as a “Large Business.” The firm calculates its base amount (the average of its MQREs over the three prior years) and can claim a 3% credit on expenses up to that base, plus a 10% credit on excess MQREs, capped at $2,000,000 annually. This significantly offsets its Michigan Corporate Income Tax (CIT) liability.

Case Study: Medical Device and Precision Machining

Historical Development in Livonia: During the globalization and contraction of the American automotive industry in the late 20th century, Livonia’s massive ecosystem of tool and die makers faced an existential threat. However, these facilities possessed highly advanced, capital-intensive Computer Numerical Control (CNC) machinery and a workforce fluent in extreme metallurgical tolerances. Consequently, many of these machine shops diversified into the medical device industry, which demands uncompromising precision for instruments that impact human health. Today, Livonia hosts numerous medical device manufacturers and precision machining firms, such as ARCH Medical Solutions, which leverage the region’s historical manufacturing prowess to produce biocompatible implants, surgical robotics components, and complex diagnostic equipment.

Example of Qualifying Activity: A Livonia-based precision manufacturer receives a conceptual design for a multi-component articulating titanium spinal implant from a medical OEM. The manufacturer must determine the optimal “speeds and feeds” to mill the complex, microscopic geometries into the titanium without causing the metal to warp from thermal friction or causing the cutting tools to shatter. Machinists and manufacturing engineers conduct systemic trial runs on 5-axis CNC machines, altering spindle speeds, coolant application, and tool pathways, subsequently inspecting each prototype under coordinate measuring machines (CMMs) to ensure the parts meet strict FDA tolerances (within ±0.0002 inches).

Detailed Analysis of Tax Credit Eligibility:

• Federal Law and Guidance: While routine manufacturing is expressly excluded from the R&D credit, the development of a new manufacturing process qualifies. The business component is the novel machining process itself. The uncertainty lies in the capability to machine the titanium to exact specifications without defect. The systematic adjustment of the CNC parameters and subsequent metallurgical inspections fulfill the process of experimentation requirement, relying firmly on materials science and mechanical engineering.
• Case Law Implications: The manufacturer must be acutely aware of the precedent set by Union Carbide Corp. v. Commissioner (2012). During the trial runs, if the CNC machine successfully cuts a spinal implant that meets all specifications, and the manufacturer eventually sells that specific prototype to the OEM, the cost of the raw titanium blank will likely be disallowed by the IRS as an ordinary, indirect production cost. Only the titanium blanks that are scrapped, destroyed, or purely used for testing without subsequent commercialization should be claimed as supply QREs. Additionally, following the ruling in Phoenix Design Group, Inc. v. Commissioner (2024), the manufacturer must maintain detailed, contemporaneous logs of the specific parameter adjustments made during each trial run; post-project estimations will not survive audit scrutiny.
• Michigan State Law (PA 186/187): Because the experimental machining occurs entirely within the Livonia plant, the wages of the manufacturing engineers and CNC programmers, along with the cost of scrapped titanium, qualify as MQREs. If this contract manufacturer employs fewer than 250 individuals, it benefits from the highly lucrative “Small Business” tier of the Michigan credit. This allows the firm to claim a 15% credit on MQREs that exceed its historical base amount, subject to a $250,000 annual maximum, providing vital capital to reinvest in next-generation robotic machining centers.

Case Study: Advanced Food Processing and Formulations

Historical Development in Livonia: Before the dominance of the automobile, Livonia’s economy was driven by agriculture and food production. Although the physical farms were eventually replaced by industrial parks, the region retained its identity as a center for food processing due to its strategic logistical advantages. The central location, robust municipal water infrastructure, and direct access to major highways made Livonia highly attractive for large-scale corporate bakeries and food manufacturers. Notably, Frito-Lay (a subsidiary of PepsiCo) established a massive manufacturing footprint in Livonia. The snack food industry requires immense capital investment in continuous-production cooking lines and complex chemical formulations to ensure shelf stability, making Livonia an ideal hub for high-volume food processing R&D.

Example of Qualifying Activity: A multinational food manufacturer operating a large plant in Livonia is tasked with reducing the sodium content of a flagship snack product by 25% while maintaining the product’s precise oxidative stability (shelf life) and structural integrity during transit. Food scientists and chemical engineers experiment with novel, proprietary preservative mixtures and alter the thermal parameters of the industrial cooking vats. They produce prototype batches, testing the new formulations in a laboratory for pH levels, brix levels, moisture content, and microbiological degradation over time.

Detailed Analysis of Tax Credit Eligibility:

• Federal Law and Guidance: Food formulation is a heavily scrutinized sector under IRC Section 41. The IRS rigorously enforces the exclusion for research related to “style, taste, cosmetic, or seasonal design factors”. If the research merely involves changing a seasoning profile for consumer preference, it fails the qualified purpose test. However, this specific scenario qualifies because the primary uncertainty is technical: achieving structural integrity and microbiological stability within a reduced-sodium chemical matrix. The process of experimentation relies on the biological sciences and chemistry (testing pH, moisture, and oxidation), not culinary arts. The wages of the food scientists and the raw ingredients consumed in the prototype batches qualify as QREs.
• Case Law Implications: The manufacturer must ensure that any prototype batches sold to the public are properly accounted for, again referencing the Union Carbide doctrine regarding supply costs. If a prototype batch of low-sodium chips is packaged and sold in test markets, the ingredients used in that batch lose their status as qualified supply expenses, though the scientists’ wages remain eligible.
• Michigan State Law (PA 186/187): The manufacturer can claim the Michigan R&D credit for the activities taking place in its Livonia testing facility. As a massive corporation, it falls under the Large Business tier. Furthermore, the legislation explicitly encourages academic partnerships. If the company collaborates with the nearby Michigan State University (MSU) Office of Research and Innovation—which possesses deep infrastructure for agricultural and chemical research—to conduct third-party validation on the new preservative compounds, the manufacturer can claim an additional 5% bonus credit on those specific university-paid MQREs, up to an extra $200,000 per year, provided a written agreement is executed.

Case Study: Defense and Aerospace Manufacturing

Historical Development in Livonia: During World War II, the broader Detroit region earned the title “Arsenal of Democracy” by converting its unparalleled automotive manufacturing capacity to the mass production of tanks, aircraft, and munitions. This historical mobilization embedded a deep intelligence regarding military specifications and defense contracting within the local workforce. In the modern era, as automotive suppliers in Livonia sought to expand their revenue streams, many leveraged their sophisticated rapid-prototyping and precision engineering capabilities to enter the aerospace and defense sectors. Facilities like the Plymouth Road Technical Center now house divisions of companies like Roush that handle classified defense prototyping, while local gear manufacturers produce high-tolerance components for military aviation.

Example of Qualifying Activity: A defense contractor located in Livonia is awarded a contract by the Department of Defense (DoD) to develop a new, lightweight composite armor panel for tactical ground mobility vehicles. The armor must withstand specific high-velocity ballistic impacts while weighing 30% less than conventional steel plating. The company’s metallurgical and chemical engineers experiment with bonding various advanced polymer and ceramic layers. They utilize finite element analysis (FEA) software to simulate ballistic stress distributions before manufacturing physical test panels for live-fire destructive testing.

Detailed Analysis of Tax Credit Eligibility:

• Federal Law and Guidance: The development of advanced composite armor clearly satisfies the technological in nature and process of experimentation tests, relying heavily on materials science and physics. However, defense contractors face severe scrutiny regarding the “Funded Research” statutory exclusion under IRC § 41(d)(4)(H).
• Case Law Implications: Relying on the strict interpretation affirmed in Meyer, Borgman & Johnson, Inc. v. Commissioner (2024), the contractor must undergo an exhaustive contract review. If the DoD contract is structured as “Cost-Plus” (where the government reimburses the contractor for all R&D expenses regardless of whether the armor successfully meets the ballistic requirements), the research is legally “funded,” and zero credits can be claimed. To claim the credit, the contract must be “Firm-Fixed-Price,” thereby shifting the economic risk of failure to the contractor. Furthermore, the contractor must retain “substantial rights” to the research results. If the DoD claims exclusive, restrictive ownership over the composite bonding formula, the taxpayer fails the rights test and is ineligible for the credit.
• Michigan State Law (PA 186/187): Assuming the contract satisfies the financial risk and IP retention requirements, the materials entirely consumed in the live-fire destructive testing and the salaries of the Livonia-based engineers qualify as MQREs. Because the defense and aerospace industries rely on capital-intensive prototypes, these expenses can escalate rapidly. The firm must accurately calculate its base amount and submit a tentative claim through the Michigan Treasury Online (MTO) portal by the strict April 1, 2026 deadline (for the 2025 tax year) to ensure it secures a portion of the capped $100 million state fund.

Case Study: Logistics Automation, Robotics, and Software

Historical Development in Livonia: The relentless drive to improve efficiency, output speed, and safety on automotive assembly lines birthed the modern industrial robotics industry. Michigan remains the national leader for employment in industries related to Industry 4.0 and automation. As automotive OEMs demanded faster cycle times, a robust ecosystem of robotics integrators, Programmable Logic Controller (PLC) programmers, and automation engineers flourished in Livonia. In recent years, the explosion of e-commerce has brought massive fulfillment centers—such as those operated by Amazon and UPS—to Livonia, creating a secondary market for this localized automation expertise. Companies that previously programmed robots to weld car chassis are now designing custom automated work cells for high-speed logistics and package sortation.

Example of Qualifying Activity: A robotics integration firm in Livonia is hired by a major e-commerce logistics center to design a custom automated sortation system. The system must utilize robotic arms equipped with novel 3D machine vision to identify, grasp, and route irregularly shaped, fragile packages moving on a high-speed conveyor belt. The firm’s software engineers must write custom algorithms to process the camera data in milliseconds to calculate the optimal grasp point, while mechanical engineers design a custom pneumatic end-effector (gripper) capable of handling highly variable weights without crushing the items.

Detailed Analysis of Tax Credit Eligibility:

• Federal Law and Guidance: The development of the hardware (the custom gripper) and the software (the machine vision algorithm) must be evaluated as separate business components under the “shrinking-back” rule. Under IRS guidance, if software is developed solely for the taxpayer’s internal administrative use, it faces a highly restrictive “High Threshold of Innovation” test. However, because this software is being developed to be integrated into hardware sold and deployed to a third party (the logistics center), it avoids the internal-use software exclusion. The iterative programming of the vision systems involves significant technical uncertainty regarding latency, algorithmic logic, and lighting compensation, qualifying under the computer science requirement.
• Case Law Implications: The integration firm must heed the warnings of Phoenix Design Group, Inc. v. Commissioner (2024). Simply connecting an off-the-shelf robotic arm to an off-the-shelf camera does not constitute R&D. The IRS frequently challenges systems integrators, asserting they are merely applying known engineering practices to adapt existing components (violating the Adaptation exclusion). The firm must meticulously document the specific architectural challenges of the vision algorithm and the systematic, trial-and-error coding processes required to achieve the unprecedented cycle times demanded by the client.
• Michigan State Law (PA 186/187): Under the Michigan statute, the wages of the software engineers and mechanical designers working in the Livonia facility are fully eligible MQREs. Because software development relies almost entirely on human capital rather than physical supplies, the precise allocation of W-2 Box 1 wages will drive the credit. If the firm is structured as an S Corporation (a flow-through entity), the entity itself files the tentative claim and claims the finalized credit on its annual withholding tax return (Form 5081), directly reducing its periodic withholding payments to the state.

Detailed Analysis of United States Federal R&D Tax Credit Laws and Guidance

The United States federal government utilizes the Research and Development tax credit, codified under Section 41 of the Internal Revenue Code (IRC), as a primary macroeconomic lever to stimulate technological advancement and maintain the nation’s competitive stance in the global economy. Originally enacted on a temporary basis in 1981, the credit provides a non-refundable, dollar-for-dollar reduction in a taxpayer’s federal income tax liability based on the incremental increase of their Qualified Research Expenses (QREs).

The Statutory Framework: The Four-Part Test

The foundation of the federal R&D tax credit is the statutory definition of “qualified research.” IRC Section 41(d) mandates that every specific research activity—analyzed down to the level of the individual business component—must satisfy a rigorous four-part test. Failure to meet any single element of this test renders the associated expenses entirely ineligible.

Statutory Exclusions

Even if an activity seemingly meets the four-part test, IRC Section 41(d)(4) explicitly outlines specific activities for which the credit is categorically disallowed. For industrial manufacturers and software developers in regions like Livonia, the most perilous exclusions include:

• Research After Commercial Production: Any research conducted after the business component has met its basic design specifications and is deemed ready for commercial production or use. Troubleshooting routine production disruptions is not qualified research.
• Adaptation of Existing Business Components: Expenditures related to adapting an existing product or process to a particular customer’s requirement or need. This exclusion frequently targets job shops and systems integrators who combine existing technologies without creating novel underlying capabilities.
• Funded Research: Any research funded by a grant, contract, or otherwise by another person or governmental entity. As discussed in the case studies, taxpayers must prove they bear the financial risk of the research’s failure and retain substantial rights to the intellectual property developed.
• Foreign Research: The federal credit is strictly a domestic incentive; all qualified research must be conducted within the United States or its territories.

Treasury Guidance and Administrative Scrutiny

The Internal Revenue Service (IRS) has steadily increased its administrative scrutiny of R&D credit claims. Recent guidance underscores the necessity of granular documentation. Historically, taxpayers could submit high-level project summaries, but revised guidelines and adjustments to IRS Form 6765 (Credit for Increasing Research Activities) implemented for the 2024 tax year demand significantly more detail.

Under current IRS directives, a taxpayer’s refund claim is only valid if they explicitly identify all business components to which the claim relates for that year, identify all research activities performed for each component, and identify all individuals who performed each activity, including the specific information each individual sought to discover. While a June 2024 update relaxed the requirement to list the names of every individual upfront on the form, the taxpayer must still maintain this granular data internally to substantiate the claim during an audit.

The Evolution of Federal Case Law

Federal case law serves as the ultimate arbiter of how IRC Section 41 is applied to complex industrial scenarios. Recent rulings have generally trended toward requiring stricter quantitative substantiation from taxpayers.

Substantiating the Process of Experimentation: Little Sandy Coal Co. v. Commissioner In the landmark 2021 Tax Court case Little Sandy Coal Co. v. Commissioner (affirmed by the Seventh Circuit in 2023), the court denied R&D credits related to the design of a tanker vessel. The core issue was the “substantially all” requirement within the process of experimentation test. The taxpayer relied on generalized assertions of engineering novelty and arbitrary estimates of the time employees spent experimenting. The appellate court affirmed that generalized descriptions of uncertainty are insufficient; taxpayers must provide a principled, quantitative method (e.g., detailed time-tracking logs) to prove that at least 80% of the claimed activities constituted actual experimentation rather than routine engineering or direct supervision.

The Engineering Design Trap: Phoenix Design Group, Inc. v. Commissioner Decided in December 2024, Phoenix Design Group further clarified the boundary between standard professional engineering and qualified R&D. The Tax Court denied credits to an engineering firm designing mechanical, electrical, and plumbing (MEPF) systems. The court ruled that following a standard, multi-stage engineering design process does not automatically equate to a process of experimentation. The firm lacked contemporaneous documentation proving that they faced specific technical uncertainties at the project’s outset or that they systematically evaluated alternatives through modeling or testing to resolve those uncertainties. The imposition of a 20% accuracy-related penalty in this case signals the IRS’s aggressive stance against inadequately documented claims.

The Commercialization of Experimental Supplies: Union Carbide Corp. v. Commissioner Union Carbide (Tax Court 2009, Second Circuit 2012) established a critical precedent regarding supply costs in manufacturing environments. The chemical manufacturer claimed the costs of raw materials run through an experimental production process. Because the experimental process did not alter the quality of the final chemicals, and the manufacturer successfully sold the resulting product, the courts ruled the supplies were ordinary, indirect production costs rather than direct research expenditures. This ruling dictates that manufacturers in Livonia cannot claim the cost of materials used in trial runs if the resulting prototype is ultimately sold to a customer as a commercial product.

Detailed Analysis of Michigan State R&D Tax Credit Laws and Guidance

While the federal R&D credit provides a baseline incentive, states frequently layer their own tax credits to attract high-tech industries and prevent corporate flight. After allowing its previous R&D incentive to sunset in the early 2010s, the State of Michigan recognized the critical need to stimulate its innovation economy against aggressive national competition. On January 13, 2025, Governor Gretchen Whitmer signed House Bills 5100 and 5101 into law (Public Acts 186 and 187 of 2024), effectively re-establishing a robust, refundable Michigan R&D tax credit for tax years beginning on and after January 1, 2025.

Statutory Mechanics and Eligibility

The Michigan R&D credit is designed as an incremental, refundable tax credit. It is accessible to two primary categories of taxpayers: Corporate Income Tax (CIT) taxpayers (C Corporations) and flow-through entities (e.g., S Corporations, Partnerships, LLCs) that are employers subject to Michigan income tax withholding.

To calculate the credit, the state utilizes the concept of Michigan Qualified Research Expenses (MQREs). Michigan legally adopts the federal definition of qualified research expenses as outlined in IRC Section 41(b)—encompassing researcher W-2 wages, consumed supplies, and 65% of contract research expenses—but with a vital geographic stricture: the research activities must physically occur within the state of Michigan. Research conducted out-of-state, even by a Michigan-headquartered company, is wholly excluded.

The Tiered Calculation Structure

Unlike the federal code, which offers complex alternative calculation methods (such as the Alternative Simplified Credit), Michigan employs a strict base-amount methodology. The “base amount” is calculated as the average annual MQREs incurred by the taxpayer during the three immediately preceding calendar years. The credit is then calculated based on the taxpayer’s size, deliberately offering superior rates to small businesses to stimulate new firm formation and entrepreneurship.

The University Collaboration Bonus: Recognizing the vast R&D infrastructure residing within the state’s academic institutions, the legislation includes a specific provision to bridge industry and academia. Businesses that engage in collaborative research with an eligible Michigan research university (defined as public universities or independent nonprofit colleges within the state) can claim an additional 5% bonus credit on the qualifying expenses associated with that collaboration. This bonus is capped at $200,000 annually per taxpayer and requires a formal written agreement to substantiate the partnership.

Treasury Administration and the Proration Mechanism

Because the Michigan R&D credit is refundable (meaning if the credit exceeds the taxpayer’s tax liability, the state pays out the difference in cash), the legislature imposed a strict macroeconomic control: an aggregate statewide cap of $100 million per calendar year. This $100 million is segmented, reserving $25 million specifically for the Small Business pool and $75 million for the Large Business pool.

To administer this cap, the Michigan Department of Treasury issued binding guidance in April 2025 requiring a “Tentative Claim” process. Taxpayers cannot simply claim the credit on their year-end return as they do federally. Instead, they must proactively apply for the credit through the Michigan Treasury Online (MTO) portal.

For MQREs incurred during the 2025 calendar year, all claimants—regardless of whether they operate on a calendar or fiscal year—must submit their tentative claims to the Treasury no later than April 1, 2026. For all subsequent years, this statutory deadline accelerates to March 15. Crucially, the Treasury mandates that these tentative claims must be calculated using actual finalized expenses, not financial estimates. The Treasury will not accept any late submissions.

If the sum of all statewide tentative claims exceeds the $100 million cap (or the respective small/large pools), the Treasury will apply a statutory proration, reducing every claimant’s allowed credit by a proportional percentage. The Treasury will subsequently issue a tentative claim adjustment notice to the taxpayers, who must then use this finalized, prorated amount when filing their annual CIT return or their annual withholding tax return (Form 5081 for flow-through entities).

Final Thoughts

Livonia, Michigan stands as a testament to industrial evolution, having transitioned from an agrarian landscape to a vital nexus of advanced manufacturing, defense engineering, and industrial automation. The reintroduction of the Michigan R&D Tax Credit under Public Acts 186 and 187 of 2024, operating synchronously with the federal IRC Section 41 credit, creates a highly favorable financial architecture to support the massive capital expenditures required for this continuous technological adaptation.

However, realizing these financial benefits requires meticulous compliance. As federal case law demonstrates, the IRS demands rigorous, contemporaneous documentation to substantiate that a true process of experimentation occurred, and that standard engineering design or ordinary production costs are not inappropriately claimed. Simultaneously, the State of Michigan’s strict tentative claim deadlines and $100 million aggregate cap demand rapid and precise financial accounting at the calendar year-end. By understanding the intricate nuances of both the federal four-part test and the state’s tiered administrative procedures, industrial enterprises in Livonia can effectively subsidize their innovation, securing the capital necessary to drive the next generation of American manufacturing.

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.