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19 February 2015


  • William A. Schmalzl
    T +1 312 701 7225
  • Michael J. Kaupa
    T +1 312 701 8209

Suder v. Commissioner, T.C. Memo. 2014-201: A Swiss Army Knife for Your Research Credit Claim

Section 41 of the US Tax Code provides a credit for increasing research activities. However, successfully claiming that credit is often more difficult than one would initially expect.

IRS statistics on taxpayer filings for uncertain tax positions (Schedule UTP) show that research credit issues are included in 19 percent or more of all UTP filings for each year between 2010 and 2013. This gives the research credit the dubious honor of being the issue most-often reported in each of these years. Further, relatively few Section 41 disputes have resulted in published opinions, and most of those tend to focus on narrow issues.

Please join William Schmalzl and Michael Kaupa from Mayer Brown’s Tax Controversy practice for an interactive discussion covering:

  • The effect of the recent Tax Court decision in Suder v. Commissioner
  • How Suder differs from other decisions by dealing with factual patterns that are common in the business community
  • Recommendations on how arguments frequently made by the IRS in audits of research credit claims can be answered by comparing your company’s claim to the court’s analysis in Suder

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