Lockheed Martin Corp. v. United States

Opinion and Order

(“Substantial rights” issue)

WEINSTEIN, Judge.

Plaintiff, Lockheed Martin Corp. (“Lockheed”), seeks a refund of $63,745,727 in federal income taxes for tax years 1984-19881, representing qualified research expenditure (“QRE”) tax credits to which plaintiff contends it was entitled for certain research expenses it incurred during the calendar years 1982 through 1988 in the performance of over 300 contracts with government and private entities. The Internal Revenue Service (“IRS”) disallowed the research tax credits sought in this refund action on the grounds that the research…