An electronics and communications manufacturing company with $400M annual revenue with engineering and technology headquarters and manufacturing locations in the US has been claiming the Research Tax Credit (RTC) since 2010. The company was generating net operating losses (NOLs) and was about to use the last of its NOLs and all carry-forward credits in the next year. As such, the company would start to utilize RTCs generated in 2010 onward. However, the company had not had a technical study conducted, and historically only completed a rough calculation of the federal RTC to capture on an F6765 for filing purposes. The new Tax Director was concerned about their potential audit risk without any technical substantiation.