26 C.F.R. § 1.41-5
Basic research for taxable years beginning after December 31, 1986. [Reserved]
Notes of Decisions
Cited in 8
cases (1 in the last 5 years), 1980–2023 · leading case: McManus v. Comm'r, 54 T.C.M. 475 (Tax Ct. 1987).
McManus v. Comm'r, 54 T.C.M. 475 (Tax Ct. 1987). “There is nothing in the record to support petitioner's characterization of the contribution. If an amount was contributed, it was not contributed by petitioner.”
Norwest Corp. v. Comm'r, 110 T.C. 454 (Tax Ct. 1998). “(applying to the pre-1986 version of the R&E credit but cross-referenced by section 1.”
Fairchild Indus., Inc. v. United States, 71 F.3d 868 (Fed. Cir. 1996). “41-5(d)(l), 26 C.F.R. § 1.41-5 (d)(l), sets the criterion for “funded” on which this case turns, viz.”
United States v. Grigsby, 86 F.4th 602 (5th Cir. 2023). “Fairchild interpreted 26 C.F.R § 1.41-5, which was redesignated as § 1.”
Rothfeld v. Comm'r, 40 T.C.M. 1162 (Tax Ct. 1980). “, 3 provides that in order for a taxpayer to be entitled to a deduction under section 218 for a political contribution he "must have a written receipt to substantiate any claim that a contribution was made.”
Fellrath v. Comm'r, 42 T.C.M. 939 (Tax Ct. 1981). “In our findings of fact we found that *294 petitioner expended $ 1,650 for office furniture, $ 20 for political contributions, and $ 9 for rent for the safe deposit box. Accordingly, we hold that he is entitled to a deduction for political contributions in the amount of $ 20,…”
Gen. Dynamics Corp. v. Comm'r, 1996 T.C. Memo. 153 (Tax Ct. 1996). “The question of whether the research was funded is dependent on whether the amounts petitioner received under the fixed-price Government contracts were "contingent on the success of the [petitioner's] research and thus considered to be paid for the product or result of the…”
Fling v. Comm'r, 41 T.C.M. 711 (Tax Ct. 1981). “Employee Business Expenses Petitioners claimed $ 950 as an employee business expense deduction which respondent disallowed in full.”
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