A sample R&D tax credit study, page by page

Everything below is synthetic. Northwind Robotics, Inc. is a fictional Pennsylvania robotics manufacturer, the roster is invented, and every dollar on this page is illustrative. What is real is the structure: these are the sheets a Ricerca study actually produces, in the order it produces them, with figures that foot to each other the way a study has to.

Read it the way a skeptic would. The interesting question is never what a vendor claims a study contains - it is whether a number on page 49 can be traced back to a person, a date and a document.

Get your free credit estimate How a study is built

The package

What a finished study hands over

Six documents. The rest of this page opens five of them and shows you a page from each.

Illustrative view of a study package. What a given engagement includes depends on the elections made and the forms its return actually needs.

1. The study report, front matter

A study is a document that has to be readable by someone who was not in the room: your preparer next spring, or an examiner three years from now. So it opens by saying what it covers and where everything is.

Study report

Illustrative - synthetic data

Research credit study, IRC §41

Northwind Robotics, Inc.

Tax year 2025, C corporation, Pennsylvania

Method elected: Alternative Simplified Credit
Form: Form 6765, Dec. 2024 revision
Business components reported: 4
Prepared by: Ricerca R&D experts

Contents

1 Engagement and scope Entity, tax year, method, and what this study does and does not cover. 3
2 Summary of the credit The computed credit, the method elected, and the §280C(c) posture. 5
3 Business components One technical narrative per component, written to the four-part test. 9
4 Qualified research expenses Workpapers by category, by employee and by component, tied to payroll and the ledger. 31
5 Base period and method The three preceding years, each substantiated, and the ASC computation. 44
6 Filing package Form 6765 including the Section G component detail, and a pro-forma Form 3800. 49
7 State position Where a state credit is computable, and where the honest answer is that it is not. 55
8 Exhibit index Every exhibit numbered, with the figure each one supports. 58

Section 1 also states the limits: the tax years covered, the entities in scope, what was excluded and why, and the fact that the return itself is signed and filed by the taxpayer’s own preparer.

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2. A technical narrative, written to the four-part test

One narrative per business component, and each one answers the four statutory questions in order rather than describing the project in general. This is the excerpt for BC-02.

Technical narrative - BC-02

Illustrative - synthetic data

BC-02, Product, reported on Form 6765 Section G

Gripper compliance controller

Held for use in the taxpayer’s own trade or business and sold as part of a packaged robotic cell. Qualified research expenses assigned to this component: $254,639.

Permitted purpose (§41(d)(1)(B)(ii), §41(d)(3))

The work was undertaken to improve the performance and reliability of the taxpayer’s existing gripper controller, which lost grip force on compliant parts above a stated cycle rate and dropped parts at a rate the line could not absorb. The improvement sought was measured against the taxpayer’s own prior controller, not against any competitor’s product. No part of the work was directed at style, taste or cosmetic factors.

Technological in nature (§41(d)(1)(B)(i), Treas. Reg. §1.41-4(a)(4))

The information sought fundamentally relied on the principles of mechanical engineering, control theory and computer science: contact-force modeling at the gripper pad, closed-loop control under sensor latency, and the numerical stability of the estimator running on the controller. The team was not required to advance any of those disciplines, only to rely on them, which is the standard the regulation sets.

Elimination of uncertainty (§41(d)(1)(A), Treas. Reg. §1.41-4(a)(3))

At the outset the information available to the taxpayer did not establish the appropriate design. It was not known whether force feedback could be estimated from motor current alone at the required update rate, or whether a discrete sensor was necessary, and if so which sensing approach would survive the coolant and debris environment of the cell. Capability was probable; method and appropriate design were open, and design uncertainty is uncertainty.

Process of experimentation (§41(d)(1)(C), Treas. Reg. §1.41-4(a)(5)-(6))

Three alternatives were identified and evaluated against a recorded test protocol: current-based force estimation, a strain-gauge pad, and a hybrid estimator corrected by an intermittent gauge reading. Each was built to a test fixture and run through a grip-and-hold matrix across part compliance, cycle rate and contamination state, with drop rate and force error recorded per run. The strain-gauge alternative was rejected on contamination failures at run 40, and the rejected branch and its measurements remain in the file. Substantially all of the research activities for this component consisted of that evaluation.

Records relied on

Time records for each named contributor, by week and by component
Tickets and commit history covering the design and rework periods
Test logs from the grip-and-hold matrix, including the rejected strain-gauge runs
Design review minutes recording the three alternatives and the decision

Every narrative in a Ricerca study carries this list. A conclusion with no record behind it does not go in the study.

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3. The QRE workpaper

Four statutory categories, and only four. The workpaper shows the amount paid, the rate at which it is includible, and the qualified figure - so the arithmetic between the ledger and the return is visible rather than asserted.

QRE workpaper - by category

Illustrative - synthetic data

Qualified research expenses by category, tax year 2025

Qualified research expenses by category, tax year 2025
Category	Statutory basis	Amount paid	Includible	QRE
Wages for qualified services	§41(b)(2)(A)(i); §3401(a)	$1,382,000	Qualified portion	$832,300
Supplies	§41(b)(2)(A)(ii)	$126,400	In full	$126,400
Computer and cloud rental	§41(b)(2)(A)(iii)	$18,900	In full	$18,900
Contract research	§41(b)(3)(A)	$188,000	65%	$122,200
Total QRE	Form 6765 Section F, line 48			$1,099,800

Illustrative, synthetic data. The wage row shows total §3401(a) wages for the population in the claim beside the qualified portion of them. Contract research is included at 65% under §41(b)(3)(A); the 75% consortium and 100% energy rates are not elective upgrades. Total carries to Section B, line 20.

Base period

2022 QRE, substantiated$611,900
2023 QRE, substantiated$704,500
2024 QRE, substantiated$786,300
Sum, Section B line 21$2,102,700

An unsubstantiated prior year blocks the study. It is never carried as a zero, because a zero would inflate the credit.

The ASC walk

Total QRE$1,099,800
Base, line 21 divided by 6.0$350,450
QRE above the base$749,350
At 14%$104,909.00
After the §280C(c) election, 79%$82,878.11

The reduced-credit election is made on a timely filed original return and is irrevocable for the year (Treas. Reg. §1.280C-4(a)).

Page 31 of 62

QRE workpaper - BC-02 wage detail

Illustrative - synthetic data

Wage QRE assigned to BC-02, Gripper compliance controller

Wage QRE assigned to BC-02, Gripper compliance controller
Employee	Role	Qualified %	Share to BC-02	Wage QRE	Basis of the percentage
A. Reyes	VP, Engineering	35%	20%	$12,950	Reviewer determined
M. Okafor	Principal Robotics Engineer	80%	25%	$33,600	Time records
D. Lindqvist	Senior Controls Engineer	75%	60%	$68,400	Time records
P. Sharma	Senior Firmware Engineer	85%	16%	$19,924	Time records
C. Batista	Mechanical Engineer II	60%	45%	$31,860	Reviewer determined
R. Duval	Manufacturing Engineer	45%	20%	$10,125	Interview memo
E. Novak	Test Engineer	65%	10%	$6,760	Time records
S. Ainsley	QA and Reliability Engineer	40%	15%	$5,760	Title benchmark (open)
T. Marchetti	Software Engineer I	55%	10%	$4,840	Title benchmark (open)
K. Osei	Prototype Lab Technician	30%	10%	$2,220	Title benchmark (open)
Total				$196,439

Illustrative, synthetic roster. Wages are §3401(a) wages; employer payroll taxes, benefits and the retirement match are outside that definition and are not in the base. Two rows rest on a suggestion a reviewer has not yet attested, and are flagged open rather than counted as settled.

Page 36 of 62

The same person appears on the workpaper for every component they touched, and their qualified percentage is stated once. That is what lets the wage column foot in two directions at the same time: down the roster, and across the components. More on what reaches the base, and what never does, on qualified research expenses.

4. The Form 6765 line map

Where every figure above lands on the return. This is a line map, not the IRS form: the line numbers, the captions and the arithmetic, so a preparer can watch the figures reconcile before anything is transcribed.

Department of the Treasury . Internal Revenue Service

Form 6765

Credit for Increasing Research Activities . Form 6765 (Rev. December 2024)

Name shown on return: Northwind Robotics, Inc.
Identifying number: XX-XXX4417
Tax year: 2025
Method elected: Section B . ASC

Section F . Qualified research expenses summary

42 In-house wages for qualified services IRC §41(b)(2)(A)(i) 832,300.00
43 Cost of supplies IRC §41(b)(2)(C) 126,400.00
44 Rental or lease cost of computers IRC §41(b)(2)(A)(iii) 18,900.00
45 Applicable percentage of contract research expenses 65% of $188,000 under IRC §41(b)(3)(A) 122,200.00
46 Basic research payments to qualified organizations IRC §41(e). None on this study 0.00
47 Add lines 45 and 46 122,200.00
48 Total qualified research expenses. Add lines 42, 43, 44 and 47 1,099,800.00

Line 48 is carried to Section B, line 20.

Section E . Other information

37 Total number of business components generating the QREs reported 4
38 Officer wages included in Section F, line 42 64,750.00

Base period behind line 21

The three preceding years are substantiated year by year. An unknown year blocks the study; it is never carried as a zero.

2022	Substantiated, consistent basis	$611,900
2023	Substantiated, consistent basis	$704,500
2024	Substantiated, consistent basis	$786,300
Sum, carried to line 21		$2,102,700
Divided by 6.0, to line 22		$350,450

Section B . Alternative simplified credit

14 Certain amounts paid or incurred to energy consortia 0.00
15 Basic research payments to qualified organizations 0.00
16 Qualified organization base period amount 0.00
17 Subtract line 16 from line 15 0.00
18 Add lines 14 and 17 0.00
19 Multiply line 18 by 20% (0.20) 0.00
20 Total qualified research expenses From Section F, line 48 1,099,800.00
21 Total QREs for the 3 preceding tax years 2022 $611,900 . 2023 $704,500 . 2024 $786,300 2,102,700.00
22 Divide line 21 by 6.0 50% of the 3-year average 350,450.00
23 Subtract line 22 from line 20. If zero or less, enter -0- 749,350.00
24 Multiply line 23 by 14% (0.14) 104,909.00
25 Add lines 19 and 24 104,909.00
26 Reduced credit under section 280C. Multiply line 25 by 79% (0.79) Election under §280C(c)(2), made on the original return. Treas. Reg. §1.280C-4(a) 82,878.11

Section C . Current year credit

27 Portion attributable to a differential wage payment credit offset 0.00
28 ASC, whichever method is elected From Section B, line 26 82,878.11
29 Research credit from pass-through entities 0.00
30 Current year research credit. Add lines 28 and 29 82,878.11
31 Estates and trusts: amount allocated to beneficiaries 0.00
32 Subtract line 31 from line 30. Current year credit carried to Form 3800 82,878.11

Section G . Business component information

Business component	Type	Wages	Supplies	Contract	Computer	Total QRE
BC-01 Vision-guided pick cell	Process	$270,538	$41,200	$53,000	$6,300	$371,038
BC-02 Gripper compliance controller	Product	$196,439	$22,800	$31,200	$4,200	$254,639
BC-03 Conveyor tracking firmware	Software	$199,248	$9,600	$21,400	$6,800	$237,048
BC-04 Thermal-tolerance test rig	Process	$166,075	$52,800	$16,600	$1,600	$237,075
Total, all components		$832,300	$126,400	$122,200	$18,900	$1,099,800

Illustrative - synthetic data. A line map of the figures a study produces, not the IRS form and not a filed return. Form 6765 . page 1 of 2

Section G is the part that changed behavior: component-level detail is reported on the return itself, in descending order by QRE. A study that already resolves to the business component populates it directly. See documentation and substantiation for the phase-in and the exceptions, and confirm both against the current-year instructions.

5. The audit-defense binder index

The last sheet is the one nobody reads until it matters. Every exhibit is numbered, and every exhibit names the figure it supports - so an information-document request is answered by pulling a labelled item rather than by reconstructing a year.

Exhibit index

Illustrative - synthetic data

Audit-defense binder index, tax year 2025

Audit-defense binder index, tax year 2025
Exhibit	Document	Supports
A-1	Payroll register, tax year 2025, all employees with titles	Wage QRE, every row of the allocation workpaper
A-2	Time records and reviewer determinations behind each qualified percentage	The qualified percentage on every allocated row
A-3	Officer wage schedule	Form 6765 Section E, line 38
B-1	General-ledger detail for supply accounts, with a sampled invoice set	Supplies QRE
B-2	Cloud and compute invoices by tagged account and environment	Computer rental QRE
B-3	Contracts, statements of work and invoices for claimed contract research	Contract research at 65%, and the rights-and-risk analysis
C-1	Design review minutes, trade studies and architecture decision records	Process of experimentation, each business component
C-2	Test plans, bench results and first-article measurements	Elimination of uncertainty and the alternatives evaluated
C-3	Ticket and commit history for the period of the work	Dates, named people, and the activity behind each narrative
D-1	Prior-year Forms 6765 and the substantiated base-period QRE for 2022, 2023 and 2024	Section B line 21, the three preceding years behind the ASC base on line 22
D-2	Interview memoranda, by technical lead	Component identification and the four-part test conclusions
E-1	Study report, QRE workpapers and the Form 6765 package as issued	The claim as filed

Illustrative. An exhibit index is not a statutory requirement; §6001 and Treas. Reg. §1.41-4(d) require records in sufficiently usable form and detail, and an index is how a file stays usable three years later.

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6. What the client receives

Two captures from the platform, on a synthetic study that was taken all the way through to a finalized, issued set of documents.

The client portal's document list: each issued document labelled current or superseded, with a plain-English note about whether it is filed with the return or kept with the records. — What the client sees: the issued document set, each one labelled current or superseded and told in plain English whether it is filed with a return or kept with the records. The 'CPA team' named on screen is the client's own firm, not Ricerca. Synthetic study data.

Superseded versions stay visible rather than vanishing. A client who is asked, years later, what they were given and when can answer from this screen.

Page one of a generated pro-forma Form 6765 showing the taxpayer block, the Section 280C election, and the Section B alternative simplified credit computed line by line. — Page one of a real generated pro-forma Form 6765, produced by the platform from a synthetic staging study. Not a filed return.

The line map above is how the figures reconcile; this is the document the platform actually generates from them, ready for the preparer who signs and files the return.

Next: how a study is built for the six phases behind these sheets, or Audit Protection for what happens if the claim is examined.

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