Union Carbide Corp. & Subsidiaries v. Commissioner
Court of Appeals for the Second Circuit
1Opinion of the Court
Judge POOLER concurs in the judgment and opinion of the Court and files a separate concurrence.
EDWARD R. KORMAN, District Judge:
Union Carbide Corporation (“UCC”) conducted three research projects at two production plants in Hahnville, Louisiana, during the 1994 and 1995 tax-credit years. The research was conducted on products that were in the process of being manufactured for sale and were in fact sold. Nevertheless, UCC requested a research credit not just for the additional costs of supplies associated with the research. Instead, it requested a research credit for the costs of all the…
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