IRC §41 qualification criteria, QRE documentation controls, and audit defense readiness for industrial operators. 40 documentation controls with IRS risk ratings — built from 89 R&D engagements and 14 IRS audit defenses.
| Section | Controls | Focus |
|---|---|---|
| Four-Part Test Qualification | 12 | Technological uncertainty, process of experimentation |
| QRE Documentation | 12 | Qualified research expenses, contemporaneous records |
| Excluded Activities & Carve-Outs | 8 | Funded research, foreign, adaptation, surveys |
| Audit Defense Readiness | 8 | Witness prep, documentation sufficiency, IDR response |
From qualifying the activity through defending the credit
No. This is the documentation framework that supports a credit study. Your CPA or Big-4 team runs the study and calculates the credit. This framework ensures the underlying documentation meets IRS examination standards.
This framework covers federal IRC §41 only. Many state credits conform to federal standards, but state-specific requirements are not included.
Each control is rated HIGH, MEDIUM, or LOW based on audit exposure if documentation is absent. HIGH items create material adjustment risk. This prioritizes your documentation effort where it matters most.
A former Big-4 consultant with 89 R&D consulting engagements across KPMG and EY, covering $1B+ aggregate credit exposure and 14 IRS audit defense proceedings.
40 controls. 4 sections. IRS risk-rated. Built from 89 engagements and 14 audit defenses.