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2021 76th Annual Conference


WED05 - Research Credit Audits after Little Sandy Coal


Oct 27, 2021 9:45am ‐ Oct 27, 2021 10:45am

Description

The Tax Court’s recent decision in Little Sandy Coal Company, Inc. v. Commissioner, has had an immediate impact on research credit examinations, emboldening revenue agents to challenge taxpayer positions on the elements of a process of experimentation. This session brings together leading research credit specialists from law, accounting, and research credit specialty firms to evaluate the opinion and its wide-ranging impacts. Panelists will address what has changed in research credit audits since Little Sandy Coal, how taxpayers should prepare for examinations in this new landscape, questions and information requests taxpayers should expect to see in IDRs, critical positions taxpayers will need to sustain to prevail, and impacts on Appeals’ consideration of research credit issues.

At the conclusion of this course, participants should:

  • Have a more informed understanding of the Tax Court’s holdings in Little Sandy Coal and their impacts on research credit audits
  • Understand how taxpayers should prepare for examinations in this new landscape
  • Be aware of questions and information requests taxpayers should expect to see in IDRs
  • Understand critical positions taxpayers will need to sustain to prevail
  • Be aware of possible impacts the decision may have on Appeals’ consideration of research credit issues

Moderator(s):

Speaker(s):

Tags: FED IRSAA

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