Loren M. Opper
Miller Canfield PLC
Articles
Court Boosts Actions to Avoid or Recover a Listed Transaction Penalty
USA - March 22 2022 For some time, the IRS has "listed" certain transactions as suspect. Based on a recent Sixth Circuit decision, a taxpayer against whom the IRS…
The Government's Use of Procedural Hurdles to Disallow Research Credit Refund Claims
USA - August 5 2021 The government's judicial attack on research credit refund claims has morphed from litigating the substantive nature of refund claims - whether the…
Use of Statistical Methods to Calculate Federal Income Tax Credits for Technological Research Activities
USA - July 7 2021 To claim federal income tax credits for a research project, a taxpayer must prove that the project satisfies each prong of a four-part test. In IRS…
Tax Court's Scorched-Earth Opinion Disallows Research Credits for Dress Design Activities
USA - April 23 2021 For practitioners advancing research credit claims, a recent Tax Court case is of concern because it said more than was necessary to reject the…
The Research Tax Credit and the Substantially-All Test
USA - March 4 2021 A recent United States Tax Court decision raises a high bar for taxpayers claiming federal income tax credits for research expenses. The case turned…
