A new court opinion issued by the U.S. Tax Court emphasizes the importance of contract review for the analysis and substantiation of an R&D tax credit claim. The opinion alludes to additional requirements to demonstrate a taxpayer's economic risk when conducting research. Moreover, the court points to precedence to emphasize that terms and conditions within any contract agreement are most important, and no implications or assumptions should be needed or considered to substantiate a credit claim.
Anam Lotia

As a senior R&D consultant for CTI, Anam provides a breadth of knowledge and client services to the firm. Anam earned a J.D. from Loyola University Chicago - School Law. She also studied for one year at the University of Houston Law Center and is now a licensed Texas attorney with specialization certificates in tax and advocacy. Utilizing her tax law background, Anam applies her skills towards identifying maximum credit opportunities for her clients as well as assisting in audit support efforts to protect each taxpayer's claims.
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Meyer, Borgman & Johnson, Inc. v. Commissioner— What’s in the Four Corners of the Contract?
Written by
Anam Lotia. Updated May 11, 2022.