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On April 6, 2026, the NAM filed an amicus brief in the Tax Court arguing that manufacturers are entitled to a tax credit for the cost of supplies used for qualified research expenses. In 2011, the 2nd Circuit issued a problematic ruling in Union Carbide Corp. v. IRS which allowed the IRS to grant a tax credit for expenses incurred in the research and development of new processes but deny the credit for the cost of supplies used in the development of those processes. Our amicus brief in this case argues that Union Carbide is based on overturned case law (Chevron) and buttresses an illogical interpretation of IRS regulations. Supplies are a critical element of plant-scale process research because new processes require supplies to test processes for efficacy, efficiency, safety, and environmental compliance.