As a tax lawyer who works exclusively on section 41, you're completely wrong. You should send your clients to tax consultants who know what they're talking abou

As a tax lawyer who works exclusively on section 41, you're completely wrong. You should send your clients to tax consultants who know what they're talking about because you clearly do not. Section 41 is a taxpayer centric test, so the work does not have to be "cutting edge." It merely has to resolve technical uncertainties via a process of experimentation.