U.S. Tax Court Memorandum Decision Awards Limited Research Tax Credits for Poultry Production, Rejects Penalties

The U.S. Tax Court, in a memorandum decision, held that the taxpayer was entitled to some research tax credits, but in lower amounts than claimed, for qualified research activities related to poultry production. The court found that certain trials involving vaccines, probiotics, and genetic lines qualified as research, while others lacked sufficient substantiation. The court allowed credits for qualified research expenses. However, the credits were limited to 6 percent of these amounts due to a lack of substantiation for base period expenses. The court rejected penalties, finding the taxpayer reasonably relied on advice from a tax consulting firm in claiming ...