Court Cases

Phoenix Design Group, Inc. v. Commissioner

December 23, 2024 | Travis A. Greaves, United States Tax Court Judge | Docket No. 4759-22  Short Summary  Phoenix Design Group, a Tennessee-based engineering consulting firm, claimed substantial R&D tax credits for their work performed on over 200 projects in 2013 through 2016. The IRS audited the company and denied the credits, arguing that the […]

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Jeffrey A. Harper and Katherine M. Harper v. Commissioner of Internal Revenue

May 10, 2023 | Copeland, United States Tax Court Judge | Docket No. 26176-16 Short Summary  Harper v. Commissioner involves Jeffrey and Katherine Harper, who owned and operated Harper Construction Co., a business specializing in design-build construction projects. The dispute arose after the IRS denied the Harpers’ claims for over $800,000 in federal R&D tax

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United States of America v. Dennis Quebe, et al.

January 23, 2017 | Sharon L. Ovington, United States Magistrate Judge | Case No. 3:15-cv-294  Short Summary This case involves Dennis and Linda Quebe, owners of Quebe Holdings, Inc., who claimed research and development (R&D) tax credits on their tax returns for 2009 and 2010. The IRS challenged these claims, arguing that the credits were

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Populous Holdings, Inc. v. Commissioner of Internal Revenue

December 6, 2019 | Joseph Robert Goeke, United States Tax Court Judge | Docket No. 405-17   Short Summary Populous Holdings, Inc., an architectural design firm, claimed federal research tax credits for work done under several client contracts. The IRS denied these credits, arguing that the research was “funded” by clients and therefore didn’t qualify.

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Moore v. Commissioner of Internal Revenue

April 30, 2024 | Before EASTERBROOK, JACKSON-AKIWUMI, and LEE, Circuit Judges   Short Summary This case involved Scott and Gayla Moore, owners of Nevco, Inc., who sought a tax credit for “qualified” research expenses under Section 41 of the Internal Revenue Code, specifically including the salary and bonus of Nevco’s President and COO, Gary Robert.

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Trinity Industries, Inc. v. United States of America

January 29, 2010 | David C. Godbey, United States District Judge | Docket No. 3:06-CV-0726-N   Short Summary Trinity Industries, a large shipbuilding company, filed a lawsuit against the United States government after the IRS denied its claims for research and development (R&D) tax credits related to several ships it designed and built in the

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Eric G. Suder, et al. v. Commissioner of Internal Revenue

October 1, 2014 | Vasquez, United States Tax Court Judge | Docket No. 14435-09, 14460-09, 6183-10, 6210-10   Short Summary This case involves Eric Suder and his company, Estech Systems, Inc. (ESI), who claimed federal research tax credits for developing new telephone systems and related technology. The IRS challenged whether ESI’s projects truly qualified as

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Basim Shami et al. v. Commissioner of Internal Revenue

January 23, 2014 | Priscilla R. Owen, Circuit Judge | United States Court of Appeals for the Fifth Circuit | Docket No. 12-60727   Short Summary This case involved a group of shareholders from Farouk Systems, Inc. (FSI), a company known for developing and selling hair care products, who challenged the IRS over denied research

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Meyer, Borgman & Johnson, Inc. v. Commissioner of Internal Revenue

May 6, 2024 | Benton, United States Court of Appeals for the Eighth Circuit Judge | Docket No. 23-1523   Short Summary Meyer, Borgman & Johnson, Inc. (MBJ), a structural engineering firm, challenged the Commissioner of Internal Revenue’s denial of about $190,000 in research tax credits, arguing that its work creating structural designs qualified as

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Fairchild Industries Incorporated v. United States, No. 94-5116

November 29, 1995 | Before RICH, NEWMAN, and SCHALL, Circuit Judges  Short Summary This case involves Fairchild Industries, Inc., an aerospace company, and the United States government. Fairchild entered into a contract with the Air Force to design and build a new training aircraft and later claimed research tax credits for the related expenses. The

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Geosyntec Consultants, Inc. v. United States

April 15, 2013 | Dave Lee Brannon, U.S. Magistrate Judge | Southern District of Florida | Docket No. 9:12-cv-80334   Short Summary Geosyntec Consultants, Inc. is an engineering firm that works with both public and private clients on environmental and infrastructure projects. The company filed a lawsuit against the United States after the IRS denied

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Little Sandy Coal Company, Inc. v. Commissioner of Internal Revenue

March 7, 2023 | Brennan, Circuit Judge, United States Court of Appeals for the Seventh Circuit | Docket No. 21-3145   Short Summary Little Sandy Coal Company, the parent of a shipbuilding business, claimed federal research tax credits for designing and building 11 new vessels, arguing that much of their work qualified as “research” under

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Edward J. Tangel and Beatrice C. Tangel, et al. v. Commissioner of Internal Revenue

January 11, 2021 | Judge Lauber | United States Tax Court | Docket Nos. 27268-13, 27309-13, 27371-13, 27373-13, 27374-13, 27375-13   Short Summary In this case, the Tangel family, who were shareholders in Enercon Engineering, Inc., challenged the IRS over denied research and development (R&D) tax credits. Enercon had claimed R&D credits for work done

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United States v. Arthur R. McFerrin and Dorothy F. McFerrin

June 9, 2009 | Edith Brown Clement, Circuit Judge | Fifth Circuit Court of Appeals | Docket No. 08-20377   Short Summary United States v. McFerrin involved Arthur R. McFerrin, a chemical engineer and business owner, and his wife, Dorothy, who claimed a large federal tax credit for research activities through their companies. The dispute

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Union Carbide Corporation and Subsidiaries v. Commissioner of Internal Revenue

September 7, 2012 | Edward R. Korman, Senior United States District Court Judge | Second Circuit Court of Appeals | Docket No. 11-2552   Short Summary Union Carbide Corporation and its subsidiaries took on the IRS (Commissioner of Internal Revenue) in a dispute over research tax credits. The main issue was whether Union Carbide could

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Siemer Milling Company v. Commissioner of Internal Revenue

 April 15, 2019 | David Buch, Judge | United States Tax Court | Docket No. 21655-15   Short Summary Siemer Milling Company, a family-owned business that mills and sells wheat flour, claimed research tax credits for several projects it conducted in 2011 and 2012. The IRS reviewed these claims and denied the credits, saying that

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