On January 11, 2021, the Tax Court issued a Memorandum Opinion in the case of Tangel et al. v. Commissioner (T.C. Memo. 2021-1). The issue presented in the consolidated Tangel et al. v. Commissioner cases was whether the petitioners were entitled to qualified research expense credits under IRC § 41. Background to Tangel et al. v. Commissioner The petitioners’ S corporation, Enercon, designs and produces integrated controls and switchgears for the power generation industry.  It