Federal Court Cases and Private Letter Rulings
These lists do not contain all of the court cases, private letter rulings, and field service advice memoranda individuals may rely on in evaluating claims for the research credit. The user is responsible for identifying references and conducting research pertinent to the facts at issue. The lists do not reflect changes in the law, rulings, or memoranda that may have occurred since the web page was last updated. Finally, by citing a particular reporter, the department does not endorse the use of one reporter or web site over another.
I. FEDERAL R&D CASES (This list is not all inclusive and is intended as a sample only.)
Allen TC Memo 1988-166 - Research expenses issues.
Apple 98 TC 232 - Nonstatutory employee stock options issues.
Fairchild 76 AFTR 2d 95-7707 - Research funding issues.
Lockheed 82 AFTR 2d 98-7141 - Research funding issues.
Lockheed Martin 82 AFTR 2d 00-1495 - Research funding issues.
Norwest 110 TC No 34 - Internal software development issues.
Research Inc 76 AFTR 2d 95-5688 - Research expense issues.
Sun Micro TC Memo 1995-69 - Disqualifying dispositions of stock issues.
Tax and Accounting Software Corporation, 2002-2 USTC 50,623 - Research software expense issues.
US Stationers 82 AFTR 2d 98-7488 - Internal software development issues.
II. PRIVATE LETTER RULINGS (PLRs) [This list is not all inclusive and is intended as a sample only.]
PLR 9410007 - Research funding issues.
PLR 9511001 - Research funding issues.
III. Field Service Advice (FSAs) [This list is not all inclusive and is intended as a sample only.]
FSA 200013017 - Research wafer and mask setup cost issues.
FSA 200227013 - Research calculation when there is a part year member issues.