Judge Travis A. (“Tag”) Greaves and I are lucky that Gary C. George and Robin A. George, T. C. Memo. 2026-10, filed 2/3/26, is appealable to 8 Cir, and that Judge Richard A. Posner of 7 Cir is no longer alive to berate both of us for “lame attempts at humor” (see my blogpost “There Goes the Neighborhood,” 9/3/13).

So no, the headline first hereinabove written at the head hereof is not political (perish the thought). Gary and Robin are shareholders in a multi-level industrial chicken breeding business ending in a Sub S. And the issue is passing through the Section 41 additional research credits.

Judge Tag Greaves has got a flock of chicken-and-egg one-liners. He also tells us a lot more about the breeding of small broilers and big broilers, their lives and diseases, than I for one wanted to know. Gary and Robin do win a bunch qualified research credits (hi, Judge Holmes) , but their failure to document baseline research limits them to the 6% Section 41(c)(5)(B), Reg. Section 1.41-9(c)(1) cutdown.

Judge Tag Greaves has thoroughly reviewed the Section 41 landscape. It’s a must-read for specialists, and eyeglazing for the rest of us.