Mike Tenenboym
Subscribe to Mike Tenenboym's PostsMike Tenenboym represents multinational organizations with respect to US federal income tax matters and international tax planning. His practice focuses on business taxation, particularly domestic and cross-border tax planning in connection with corporate restructurings, spin-offs, mergers, acquisitions and other major corporate transactions. Mike also handles tax policy matters, having drafted comment letters and articles with respect to the Tax Cuts and Jobs Act and CARES Act. Mike advises clients in a variety of industries, including aerospace, defense, semiconductor, pharmaceutical and telecommunications. Read Mike Tenenboym's full bio.
Pilot models at scale: What George v. Commissioner teaches about the research credit
By Akiva B. Ungar, Mike Tenenboym and Edward L. Froelich on May 15, 2026
Posted In Court Procedure Matters, Significant Court Decision, Trial Courts
The US Tax Court’s recent decision in George v. Commissioner, T.C. Memo. 2026-10, addressed the application of the Section 41 research credit to supply qualified research expenses (QREs), focusing on whether chickens used in drug trials can qualify as “supplies.” The case provides useful insight into how courts evaluate technical uncertainty under Section 174 for...
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IRS Changes Position on Approval for Assertion of Codified Economic Substance Doctrine
By Mike Tenenboym on Apr 29, 2022
Posted In IRS Audits, IRS Guidance
In March 2010, Congress codified the economic substance doctrine in Internal Revenue Code (Code) Section 7701(o). The codification clarified that a conjunctive analysis applies in determining if the doctrine applies. The codified economic substance doctrine applies when a transaction does not have economic substance or lacks a business purpose. When the doctrine applies, a taxpayer is...
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