Alan Horowitz commented on the challenges taxpayers face in claiming credits for qualified research expenses (QREs).  The comments were in response to the decision by the U.S. Court of Appeals for the Second Circuit, which held in the recent Union Carbide Corp. v. Commissioner decision that Union Carbide Corp. (UCC) could not claim the federal research credit under tax code Section 41 for supplies that were used in process research and development (R&D) activities.  "The UCC decision is a blow to manufacturers hoping for a broader reading of the R&D credit," Horowitz said, adding that "the extent of the impact remains to be seen."