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Miller Canfield

Getting an Erroneous Tax Refund Case to a Jury is a Fraught Task in the Fifth Circuit

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In Grigsby v. United States, the Justice Department used discovery procedures in federal district court essentially to audit a taxpayer’s federal income tax credits for research activities. The court found that the taxpayer...more

Miller Canfield

The Government's Use of Procedural Hurdles to Disallow Research Credit Refund Claims

Miller Canfield on

In two recent cases, the IRS has tried to defeat research credit refund claims on procedural grounds, rather than simply litigating whether the substantive nature of the asserted research meets the requirements of section 41...more

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