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UNITED THERAPEUTICS CORPORATION v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 10210-21.

160 T.C. No. 12

UNITED THERAPEUTICS CORPORATION, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed May 17, 2023.

Attorney(s) appearing for the Case

Thomas H. Dupree, Jr. , Lucas C. Townsend , Saul Mezei , and John F. Craig III , for petitioner.

Brandon S. Cline , Anna L. Boning , and Naseem Jehan Khan , for respondent.

OPINION

In this deficiency case involving the tax year 2014, we consider a question of first impression: Must expenses that are used to determine the orphan drug credit under section 45C1 also be taken into account in determining certain elements of the research credit under section 41, with the...

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