Précis: The taxpayer had previously been in the flavouring business but sold those lines and was now working on plant sterol beverages and other health foods. The taxpayer claimed SRED expense on two projects: Project 705—the Plant Sterols Beverage Project, and Project 806 - a Partial Hot Fill System. The Tax Court found that the evidence in relation to Project 705 did not disclose true scientific research. In the case of Project 806 the evidence was unclear, both in terms of when the work was done and the nature of the project. As a result the appeal was dismissed. Although the Crown asked for costs under the Informal Procedure Rules, the Court declined to award them.
Flavor Net Inc. v. R. – TCC: SRED claims either not research or not documented properlyREAD MORE »