LITTLE SANDY COAL v. COMM'R OF INTERNAL REVENUE

No. 21-3145.

62 F.4th 287 (2023)

LITTLE SANDY COAL COMPANY, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided March 7, 2023.


Attorney(s) appearing for the Case

Jeremy Fingeret , Jefferson H. Read , Attorneys, Zerbe, Fingeret, Frank & Jadav, Houston, TX, for Petitioner-Appellant.

Kathleen E. Lyon , Jennifer M. Rubin , Attorneys, Department of Justice, Tax Division, Appellate Section, Washington, DC, for Respondent-Appellee.

Joseph R. Guerra , Matthew D. Lerner , Attorneys, Sidley Austin LLP, Washington, DC, for Amiens Curiae National Association of Manufacturers.

Before Rovner, Hamilton, and Brennan, Circuit Judges.


This case requires us to interpret the research tax credit under Section 41 of the Internal Revenue Code. To claim the credit, a taxpayer must demonstrate, among other things, that at least 80 percent of its research activities for a business component constituted elements of a process of experimentation.

Taxpayer...

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