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TANGEL v. COMMISSIONER OF INTERNAL REVENUE

Docket Nos. 27268-13, 27309-13, 27371-13, 27373-13, 27374-13, 27375-13.

T.C. Memo. 2021-1

EDWARD J. TANGEL AND BEATRICE C. TANGEL, ET AL., Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed January 11, 2021.

Attorney(s) appearing for the Case

Robert G. Wonish II , Jefferson H. Read , and John H. Dies , for petitioners.

Christa A. Gruber , Mayah Solh-Cade , Danielle R. Dold , and Tess deLiefde , for respondent.

MEMORANDUM OPINION

The principal question in these consolidated cases concerns petitioners' entitlement to credits under section 41 for increasing research activities.2 The Internal Revenue Service (IRS or respondent) disallowed research credits of $929,668 claimed during 2008-2010 by Enercon...

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