Income Tax Issues
Deductions

Max v. Commissioner
T.C. Memo. 2021-37

On March 29, 2021, the Tax Court issued a Memorandum Opinion in the case of Max v. Commissioner (T.C. Memo. 2021-37). The primary issue presented in Max was whether drawing fashion sketches qualify as “qualified research” under IRC § 41. General Observations in Max v. Commissioner Who knew Judge Buch was such a fashionista? If you don’t believe me, read the first 21 pages of the opinion.  The editor of Teen Vogue better watch out.  Judge

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Scott St. Amand March 29, 2021
Business Related Issues
Costs of Experimentation

Little Sandy Coal Co. Inc. v. Commissioner
T.C. Memo. 2021-15

On February 11, 2021, the Tax Court issued a Memorandum Opinion in the case of Little Sandy Coal Co. Inc. v. Commissioner (T.C. Memo. 2021-15). The primary issue presented in Little Sandy Coal Co. Inc. v. Commissioner was whether the activities of the petitioner’s subsidiary’s research in developing the ships constituted elements of a process of experimentation for purposes of IRC § 41(d)(1)(C) and Treas. Reg. § 1.41-4(a)(6). Holdings, in Brief in Little Sandy Coal Co.

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Scott St. Amand February 11, 2021
Business Related Issues
Funded Research

Tangel et al. v. Commissioner
T.C. Memo. 2021-1

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

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Scott St. Amand January 11, 2021
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Max v. Commissioner
T.C. Memo. 2021-37

On March 29, 2021, the Tax Court issued a Memorandum Opinion in the case of Max v. Commissioner (T.C. Memo. 2021-37). The primary issue presented in Max was whether drawing fashion sketches qualify as “qualified research” under IRC § 41. General Observations in Max v. Commissioner Who knew Judge Buch

Read More »
Scott St. Amand March 29, 2021

Little Sandy Coal Co. Inc. v. Commissioner
T.C. Memo. 2021-15

On February 11, 2021, the Tax Court issued a Memorandum Opinion in the case of Little Sandy Coal Co. Inc. v. Commissioner (T.C. Memo. 2021-15). The primary issue presented in Little Sandy Coal Co. Inc. v. Commissioner was whether the activities of the petitioner’s subsidiary’s research in developing the ships constituted

Read More »
Scott St. Amand February 11, 2021

Tangel et al. v. Commissioner
T.C. Memo. 2021-1

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.

Read More »
Scott St. Amand January 11, 2021