Contingent fees in R&D tax credit claims

1Summary

The federal credit for increasing research activities under Section 41 of the Internal Revenue Code is generally 20 percent of a business's qualified research expenses above a base amount, or 14 percent under the alternative simplified method.1 Whether an activity qualifies is decided separately for each business component, under a test that requires judgment at every step.12 IRS examiner guidance has described research credit refund claims as usually based on a study prepared by an outside consultant.3

Advisers are paid in different ways. One is a contingent fee, often called a success fee: a fee calculated as a percentage of the credit or refund. Treasury's rules for practice before the IRS define a contingent fee to include exactly that.4

This paper sets out how contingent fees work in research credit claims, what the official record shows and does not show about them, and the incentives they create. It describes the professional rules that already restrict such fees and where those rules stop. It sets out the case for success fees in its strongest form, and then answers it. It finds that the fee and the credit move together, that the consequences of an overstated claim fall on the taxpayer, and that no official source measures how research credit advisers are paid. Swanson Reed's position and its response to the case for success fees are in labeled boxes.

2The research credit and how a claim is built

2.1What the credit rewards

Section 41 provides a credit equal to 20 percent of the excess of qualified research expenses over a base amount, together with amounts for basic research payments and energy research consortia.1 A taxpayer may instead elect the alternative simplified credit, which is 14 percent of qualified research expenses above 50 percent of the average for the three preceding years.1 Qualified research expenses are wages for qualified services, supplies used in qualified research, certain computer rental costs, and a percentage of contract research expenses.15

Research is qualified research only if it meets what the IRS calls the "four-part test".5 It must be research whose expenditures may be treated as research or experimental expenditures; it must be undertaken to discover information that is technological in nature; the information must be intended to be useful in developing a new or improved business component; and substantially all of the activities must constitute elements of a process of experimentation for a qualified purpose.15

2.2The business component

The test is applied separately to each business component of the taxpayer.1 A business component is any product, process, computer software, technique, formula or invention that is to be held for sale, lease or license, or used in the taxpayer's trade or business.1 If the test is not met for the whole component, the regulations apply it to the most significant subset of elements of the component, which the regulations call the shrinking-back rule.2

The "substantially all" requirement is met only if 80 percent or more of a taxpayer's research activities, measured on a cost or other consistently applied reasonable basis, are elements of a process of experimentation.2 For wages, Section 41 provides that if substantially all of an individual's services are qualified services, all of that individual's services are treated as qualified.1

2.3Where the judgment lies

Each of these rules requires a judgment about facts. Which projects are business components; which activities within them were experimentation; what share of each employee's time went to qualified services; whether supplies were used in qualified research; and, for the regular credit, how base period expenses were measured. The 2008 IRS guide for examiners of research credit claims observed that taxpayers frequently used extrapolation methods to compute base period amounts and stated that extrapolation is not an acceptable method for computing the fixed-base percentage.3

The regulations require a taxpayer claiming the credit to retain records in sufficiently usable form and detail to substantiate that the expenditures claimed are eligible.2 The IRS Office of Chief Counsel has described the research credit as a complex area of law involving a four-part test and numerous exclusions.6

2.4Original returns and refund claims

A credit can be claimed on the original return for the year, or later on an amended return or other claim for refund. A claim for refund must generally be filed within three years from the time the return was filed or two years from the time the tax was paid, whichever is later.7 Treasury regulations require a refund claim to set forth in detail each ground on which it is made and facts sufficient to apprise the Commissioner of its exact basis, and a claim that does not comply "will not be considered for any purpose as a claim for refund or credit".8 Since January 2022 the IRS has required specific information with research credit refund claims, which is the subject of a separate paper in this series.9

3How contingent fees work

3.1The definitions

Circular 230, the Treasury regulations that govern practice before the IRS, defines a contingent fee as any fee that is based, in whole or in part, on whether or not a position taken on a tax return or other filing avoids challenge by the IRS or is sustained by the IRS or in litigation.4 It states that a contingent fee "includes a fee that is based on a percentage of the refund reported on a return, that is based on a percentage of the taxes saved, or that otherwise depends on the specific result attained".4 It also includes any arrangement under which the practitioner will reimburse all or part of the client's fee if a position is challenged or not sustained, whether through an indemnity agreement, a guarantee, rescission rights or any similar arrangement.4

The AICPA Code of Professional Conduct defines a contingent fee as a fee established under an arrangement in which no fee will be charged unless a specified finding or result is attained, or in which the amount of the fee otherwise depends on the finding or result.10

3.2The forms a contingent fee can take

The definitions identify the main forms. A fee may be a percentage of the credit claimed, or of the refund that results. It may be payable only if a credit is obtained. It may be refundable, in whole or in part, if the IRS challenges or reduces the claim. Each of these falls within Treasury's definition.4

The arithmetic is simple. As an illustration only: on a claimed credit of $100,000, a fee of 20 percent would be $20,000; if the same claim were prepared to show a credit of $150,000, the same percentage would produce a fee of $30,000. The work may or may not differ between the two. The fee differs because the claim differs.

3.3What the IRS has told its examiners

The IRS published a Research Credit Claims Audit Techniques Guide in May 2008. The guide states that it is not an official pronouncement of the law or the position of the IRS and cannot be relied on as such.3 It is cited here only as a record of what the IRS told its examiners at the time.

The guide described "a growing trend among taxpayers, and their representatives, to submit prepackaged material to support research credit claims", usually delivered in multiple binders, and said those submissions "frequently fail to substantiate" that the taxpayer paid or incurred the qualified research expenses claimed.3 It said research credit refund claims are usually based on a research credit study prepared by an outside consultant under an engagement letter, and told examiners to request a copy of the engagement letter with the mandatory information request.3

On fees, the guide asked examiners to consider the following point: "If the fee is based on the ultimate determination of the claim amount there may be a limitation on to ability [sic] of the taxpayer to resolve the issue. Some fee agreements shift ultimate control over the resolution of the claim to the preparer."3

3.4What the official data shows

The IRS has said that each year it receives thousands of research credit claims for refund involving hundreds of millions of dollars, and that these claims are examined in a substantial number of cases and consume significant resources for both the IRS and taxpayers.11 The IRS Statistics of Income program publishes tables on corporations claiming the credit, but its corporation research credit tables listed on the IRS website run only to tax year 2014.12

No IRS form or publication found for this paper reports how research credit claims are prepared or how their preparers are paid. Form 6765 does not ask.5 There is no official measure of how many claims are prepared on a contingent fee, or of how claims prepared under different fee arrangements fare on examination. This paper therefore makes no estimate of either.

4The incentives a contingent fee creates

4.1The fee rises with the claim

A fee calculated as a percentage of the credit rises with the credit. That is a property of the arrangement, not a statement about anyone who uses it. Treasury has explained its own rule in these terms. When it adopted the current Circular 230 contingent fee rule in 2007, it said that "a rule restricting contingent fees for preparing tax returns supports voluntary compliance with the Federal tax laws by discouraging return positions that exploit the audit selection process", and that it was particularly concerned with contingent fees for claims for refund or amended returns filed late in the examination process.13

In December 2024 Treasury and the IRS went further. Proposing to treat contingent fees for preparing returns and refund claims as disreputable conduct, they wrote that "A practitioner with a direct, financial interest in the tax benefits of a client may be incentivized to increase such tax benefits."14 That proposal has not been finalized.14

The IRS gives the same advice to individual taxpayers in general terms: "Avoid tax return preparers who base their fees on a percentage of the refund".15

4.2Where the incentive operates

The incentive matters most where the law calls for judgment. In a research credit claim, those points include the identification of business components, the 80 percent substantially all threshold, the allocation of wages to qualified services, the treatment of supplies and contract research, and the measurement of the base amount.123 At each point, a reasonable judgment could go either way. A fee calculated on the credit pays more when each judgment goes toward a larger claim, and nothing in the fee pays more for a judgment that goes the other way.

The incentive does not mean that any adviser acts on it. Many advisers who charge contingent fees may apply the law carefully and decline weak positions. The point is that the fee structure rewards the size of the claim, while the taxpayer's interest is in a claim that is both as large as the law allows and able to survive examination.

4.3Who bears the consequences

If the IRS reduces a credit, the consequences fall in the first instance on the taxpayer.

The tax. The taxpayer repays the credit it should not have received, or loses the refund it claimed.
Interest. Interest runs on unpaid tax from the last date prescribed for payment at the underpayment rate.16
The erroneous claim penalty. If a claim for refund or credit of income tax is made for an excessive amount, the person making the claim is liable for a penalty of 20 percent of the excessive amount unless the excess is due to reasonable cause.17 The person making the claim is the taxpayer.
The accuracy-related penalty. Where an underpayment results from negligence or a substantial understatement of income tax, a penalty of 20 percent of the relevant portion of the underpayment applies.18

The preparer faces its own penalties. A tax return preparer is any person who prepares for compensation any return or claim for refund, including a substantial portion of one.19 If any part of an understatement on a return or claim is due to an unreasonable position the preparer knew or should have known of, the preparer owes the greater of $1,000 or 50 percent of the income derived from the return or claim, rising to the greater of $5,000 or 75 percent for willful or reckless conduct.20 No penalty applies under the first rule if there was reasonable cause and the preparer acted in good faith.20

No federal rule requires an adviser to refund a contingent fee when a claim is reduced. Whether a fee is refunded depends on the engagement letter. And under Treasury's definition, an arrangement to refund the fee if a position is not sustained is itself a contingent fee.4

4.4Control of the outcome

The 2008 examiner guide noted that some fee agreements "shift ultimate control over the resolution of the claim to the preparer".3 Where the fee depends on the final amount, the adviser has a financial interest in how an examination is resolved. The taxpayer may prefer to settle quickly, concede a weak item or avoid the cost of a dispute. The adviser's fee may depend on the opposite. The guide did not say how often this happened, and no later official source found for this paper measures it.

5The rules that already apply

5.1Circular 230

Circular 230 has restricted contingent fees for many years. A 2014 federal court opinion records that, beginning in 1994, Circular 230 prohibited contingent fees for preparing original income tax returns but allowed them for amended returns and refund claims.21 Treasury amended the rule in 2007, with effect for fee arrangements entered into after 26 March 2008.413

The current text provides that, except in listed cases, a practitioner may not charge a contingent fee for services rendered in connection with any matter before the IRS.4 A matter before the IRS includes "preparing or filing or assisting in preparing or filing returns or claims for refund or credit".4 The exceptions cover services in connection with an IRS examination of, or challenge to, an original return, or an amended return or refund claim filed within 120 days of a written notice of examination or challenge; claims relating solely to statutory interest or penalties; and judicial proceedings.4

5.2The AICPA Code

The AICPA Code provides that a member in public practice shall not "Prepare an original or amended tax return or claim for a tax refund for a contingent fee for any client".10 Fees determined by the findings of governmental agencies are not treated as contingent where the member can show a reasonable expectation, at the time of the arrangement, that an agency will give the matter substantive consideration. That expectation is not reasonable where the member prepares the client's original return.10 The Code gives, as an example of a fee that is not permitted, a contingent fee for an amended return claiming a refund because a valid deduction was inadvertently omitted from the original.10

5.3Where the rules stop

Circular 230 rests on Treasury's statutory authority to regulate the practice of representatives before the Department.22 In 2014 the D.C. Circuit held that this authority does not extend to regulating tax return preparers, and said that if more stringent regulation of preparers would be wise as a policy matter, "that is a decision for Congress and the President to make if they wish by enacting new legislation".22 Later in 2014 a federal district court applied that reasoning to refund claims filed after the original return but before an audit, held that the IRS lacks statutory authority to regulate their preparation and filing, and permanently enjoined enforcement of the contingent fee rule in that respect.21 The court noted that, on the IRS's reading, the rule would impose no contingent fee restrictions on the preparation of such claims by people who never practice before the IRS.21

The AICPA Code binds AICPA members.10 The IRS describes a class of paid preparers who hold a preparer tax identification number but no professional credential, and who are authorized to prepare returns.23 Neither set of fee rules reaches them unless they are otherwise covered.

The December 2024 proposal would remove the current section 10.27 and instead make it disreputable conduct to charge a contingent fee in connection with preparing an original or amended return or claim for refund prepared before examination.14 It relies on Treasury's power to sanction practitioners for disreputable conduct.14 It would therefore still apply only to practitioners, and it has not been finalized.14

6The case for success fees

A fair assessment must begin with the reasons businesses agree to contingent fees and advisers offer them. These arguments were put to Treasury when it last revised its rule. Commenters said the proposed restrictions were overly broad, improperly interfered with the practitioner and client relationship, and "prohibited some small and middle market taxpayers from appropriately requesting refunds".13 Set out in their strongest form, the arguments are these.

Access. Supporters argue that many businesses that do qualifying research do not know it, or do not know how to claim, that a contingent fee lets them find out at no upfront cost, and that without it some would never claim a credit Congress intended them to have.

Cash flow. Supporters argue that a business that is short of cash may be unable to pay a fixed fee before it knows whether a credit exists, and that a fee paid from the credit, once received, matches cost to benefit.

Risk sharing. Supporters argue that under a contingent fee the adviser bears the cost of work that produces no credit, that the business pays only if there is something to pay from, and that a fixed fee leaves that risk with the business.

Alignment and value. A fee tied to the credit moves with the value the business receives. Supporters argue that this is a fair way to price work whose value cannot be known in advance, and that it gives the adviser a reason to find every credit the business is entitled to.

Professional rules already apply. Supporters can point out that preparer penalties apply whatever the fee arrangement, and that credentialed advisers remain bound by professional duties of diligence and competence.20

These arguments describe real advantages to real businesses. Nothing in this paper suggests that advisers who charge contingent fees act improperly.

7Our answer (Swanson Reed's position)

This section is Swanson Reed's view.

Our position

7.1Access and cash flow

The access and cash flow arguments are strongest for small businesses. They are arguments for low upfront cost and predictable pricing. A fixed fee, a capped fee, or a fee paid in stages after the credit is received can meet them without calculating the fee as a share of the credit. Treasury's definition is concerned with how a fee is calculated, not with when it is paid.4

The risk a contingent fee shares is the risk that the work finds no credit. It does not share the risk that matters most to the business: that the credit claimed does not survive examination. That risk stays with the taxpayer, who repays the credit with interest and may face a 20 percent penalty.171816 Where a fee is refunded if the claim is reduced, Treasury treats the arrangement as contingent in its own right, because it gives the adviser a stake in avoiding challenge.4

7.3Alignment

A fee tied to the credit claimed is aligned with the amount claimed. It is not aligned with the amount that survives examination, which is the amount the business keeps. The difference between those two amounts is where the business and the adviser can have different interests. The 2008 examiner guide's observation about control over resolution illustrates the point.3

7.4Existing rules

The professional rules that restrict contingent fees for returns and refund claims rest on the same concern this paper describes.41014 Their limits are a matter of jurisdiction, not of principle: Treasury's practice authority does not reach return preparation or ordinary refund claims, and professional codes bind only their members.212210 Preparer penalties apply after the fact and are measured partly by the preparer's income from the claim.20 They do not address how that income is calculated.

Our position

Congress should prohibit contingent fees, commonly called success fees, in federal research and development tax credit engagements under Section 41, so that advisers are paid for the work they perform rather than for the size of the claim they produce. Swanson Reed, which publishes this paper, is a fixed-fee R&D tax adviser. It has a direct commercial interest in the outcome: it does not charge success fees, and a ban would remove a pricing model it competes against.

8What the evidence does and does not show

The case made in this paper rests on the structure of the fee, the law that governs the claim, and the stated reasoning of Treasury and the IRS. It does not rest on measured outcomes, because none are published.

What the record shows:

Treasury's own definition treats a percentage of a refund or of taxes saved as a contingent fee.4
Treasury has explained its restrictions by reference to the incentive such fees create, in 2007 and again in 2024.1314
IRS examiner guidance has described research credit refund claims as usually based on outside consultants' studies and has identified contingency fees as a point for examiners to consider.3
The financial consequences of a reduced claim fall on the taxpayer.171816
The federal fee rules do not reach every person who prepares a claim.212223

What the record does not show:

How many research credit claims are prepared on a contingent fee.
Whether claims prepared on a contingent fee are adjusted more or less often, or by more or less, than other claims.
Any current IRS statistics on research credit claims by preparer type.

Those gaps are themselves relevant. No claim form records how its preparer was paid, so the question cannot be measured from official data. Until it can be, readers, including those who disagree with the position above, should weigh the argument as one about incentives and rules rather than about measured results.

References

Office of the Law Revision Counsel, 26 U.S.C. 41, Credit for increasing research activities, subsections (a), (b)(1) and (2), (c)(4)(A), (d)(1) and (d)(2), United States Code 2024 edition published by the Government Publishing Office. https://www.govinfo.gov/content/pkg/USCODE-2024-title26/html/USCODE-2024-title26-subtitleA-chap1-subchapA-partIV-subpartD-sec41.htm (accessed 11 October 2026). Back
Treasury Department, 26 CFR 1.41-4, Qualified research for expenditures paid or incurred in taxable years ending on or after December 31, 2003, paragraphs (a)(6), (b)(2) and (d). https://www.ecfr.gov/current/title-26/section-1.41-4 (accessed 11 October 2026). Back
Internal Revenue Service, Large and Mid Size Business Division, Research Credit Claims Audit Techniques Guide (RCCATG): Credit for Increasing Research Activities Section 41, LMSB-04-0508-030 (May 2008), introductory note, Chapter I "Background" and Chapter II "How to evaluate taxpayer's responses", "Consistency and base period issues" and "The RC Claim Engagement Letter". https://www.irs.gov/businesses/research-credit-claims-audit-techniques-guide-rccatg-credit-for-increasing-research-activities-section-41 (accessed 11 October 2026). Back
Treasury Department, Circular No. 230, 31 CFR 10.27, Fees, paragraphs (b), (c) and (d). https://www.ecfr.gov/current/title-31/subtitle-A/part-10/subpart-B/section-10.27 (accessed 11 October 2026). Back
Internal Revenue Service, Instructions for Form 6765 (Rev. December 2025), "Definitions: Qualified Research" and "Business Component", and "Section F". https://www.irs.gov/instructions/i6765 (accessed 11 October 2026). Back
IRS Office of Chief Counsel, Memorandum 20214101F, I.R.C. 41 Research Credit Refund Claims, dated 17 September 2021, released 15 October 2021, Law and Analysis part C. https://www.irs.gov/pub/irs-lafa/20214101f.pdf (accessed 11 October 2026). Back
Office of the Law Revision Counsel, 26 U.S.C. 6511, Limitations on credit or refund, subsection (a), United States Code 2024 edition published by the Government Publishing Office. https://www.govinfo.gov/content/pkg/USCODE-2024-title26/html/USCODE-2024-title26-subtitleF-chap66-subchapB-sec6511.htm (accessed 11 October 2026). Back
Treasury Department, 26 CFR 301.6402-2, Claims for credit or refund, paragraph (b)(1). https://www.ecfr.gov/current/title-26/section-301.6402-2 (accessed 11 October 2026). Back
Internal Revenue Service, Research credit claims (Section 41) on amended returns frequently asked questions, introduction and question 21 (page last reviewed or updated 1 October 2026). https://www.irs.gov/businesses/corporations/research-credit-claims-section-41-on-amended-returns-frequently-asked-questions (accessed 11 October 2026). Back
American Institute of CPAs, AICPA Code of Professional Conduct (updated for all official releases through September 2026), ET 0.200.020 paragraph .02, ET 1.510.001 Contingent Fees Rule paragraphs .01 and .03, and ET 1.510.010 Tax Matters paragraphs .03 to .05. https://pub.aicpa.org/codeofconduct/ethicsresources/et-cod.pdf (accessed 11 October 2026). Back
Internal Revenue Service, IRS sets forth required information for a valid research credit claim for refund, News release IR-2021-203, 15 October 2021. https://www.irs.gov/newsroom/irs-sets-forth-required-information-for-a-valid-research-credit-claim-for-refund (accessed 11 October 2026). Back
Internal Revenue Service, SOI Tax Stats: Corporation research credit, table list. https://www.irs.gov/statistics/soi-tax-stats-corporation-research-credit (accessed 11 October 2026). Back
Treasury Department and Internal Revenue Service, Regulations Governing Practice Before the Internal Revenue Service, final regulations, T.D. 9359, 72 FR 54540 (26 September 2007), preamble, "Contingent Fees", pages 54541 to 54542. https://www.federalregister.gov/documents/2007/09/26/E7-18918/regulations-governing-practice-before-the-internal-revenue-service (accessed 11 October 2026). Back
Treasury Department and Internal Revenue Service, Regulations Governing Practice Before the Internal Revenue Service, notice of proposed rulemaking, REG-116610-20, 89 FR 104915 (26 December 2024), Explanation of Provisions part B and proposed section 10.51. https://www.federalregister.gov/documents/2024/12/26/2024-29371/regulations-governing-practice-before-the-internal-revenue-service (accessed 11 October 2026; Federal Register search on that date showed no final rule). Back
Internal Revenue Service, Topic no. 254, How to choose a tax return preparer (page last reviewed or updated 7 October 2026). https://www.irs.gov/taxtopics/tc254 (accessed 11 October 2026). Back
Office of the Law Revision Counsel, 26 U.S.C. 6601, Interest on underpayment, nonpayment, or extensions of time for payment, of tax, subsection (a), United States Code 2024 edition published by the Government Publishing Office. https://www.govinfo.gov/content/pkg/USCODE-2024-title26/html/USCODE-2024-title26-subtitleF-chap67-subchapA-sec6601.htm (accessed 11 October 2026). Back
Office of the Law Revision Counsel, 26 U.S.C. 6676, Erroneous claim for refund or credit, subsections (a) and (b), United States Code 2024 edition published by the Government Publishing Office. https://www.govinfo.gov/content/pkg/USCODE-2024-title26/html/USCODE-2024-title26-subtitleF-chap68-subchapB-partI-sec6676.htm (accessed 11 October 2026). Back
Office of the Law Revision Counsel, 26 U.S.C. 6662, Imposition of accuracy-related penalty on underpayments, subsections (a) and (b)(1) and (2), United States Code 2024 edition published by the Government Publishing Office. https://www.govinfo.gov/content/pkg/USCODE-2024-title26/html/USCODE-2024-title26-subtitleF-chap68-subchapA-partII-sec6662.htm (accessed 11 October 2026). Back
Office of the Law Revision Counsel, 26 U.S.C. 7701, Definitions, subsection (a)(36)(A), United States Code 2024 edition published by the Government Publishing Office. https://www.govinfo.gov/content/pkg/USCODE-2024-title26/html/USCODE-2024-title26-subtitleF-chap79-sec7701.htm (accessed 11 October 2026). Back
Office of the Law Revision Counsel, 26 U.S.C. 6694, Understatement of taxpayer's liability by tax return preparer, subsections (a) and (b), United States Code 2024 edition published by the Government Publishing Office. https://www.govinfo.gov/content/pkg/USCODE-2024-title26/html/USCODE-2024-title26-subtitleF-chap68-subchapB-partI-sec6694.htm (accessed 11 October 2026). Back
US District Court for the District of Columbia, Ridgely v. Lew, Civil Action No. 1:12-cv-00565 (CRC), Memorandum Opinion, 16 July 2014, pages 1, 4, 13 and 14 to 15. https://www.govinfo.gov/content/pkg/USCOURTS-dcd-1_12-cv-00565/pdf/USCOURTS-dcd-1_12-cv-00565-1.pdf (accessed 11 October 2026). Back
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Cite this paper

Summary

1Summary

2The research credit and how a claim is built

2.1What the credit rewards

2.2The business component

2.3Where the judgment lies

2.4Original returns and refund claims

3How contingent fees work

3.1The definitions

3.2The forms a contingent fee can take

3.3What the IRS has told its examiners

3.4What the official data shows

4The incentives a contingent fee creates

4.1The fee rises with the claim

4.2Where the incentive operates

4.3Who bears the consequences

4.4Control of the outcome

5The rules that already apply

5.1Circular 230

5.2The AICPA Code

5.3Where the rules stop

6The case for success fees

7Our answer (Swanson Reed's position)

7.1Access and cash flow

7.3Alignment

7.4Existing rules

8What the evidence does and does not show

References

About this paper

Cite this paper

Summary

1Summary

2The research credit and how a claim is built

2.1What the credit rewards

2.2The business component

2.3Where the judgment lies

2.4Original returns and refund claims

3How contingent fees work

3.1The definitions

3.2The forms a contingent fee can take

3.3What the IRS has told its examiners

3.4What the official data shows

4The incentives a contingent fee creates

4.1The fee rises with the claim

4.2Where the incentive operates

4.3Who bears the consequences

4.4Control of the outcome

5The rules that already apply

5.1Circular 230

5.2The AICPA Code

5.3Where the rules stop

6The case for success fees

7Our answer (Swanson Reed's position)

7.1Access and cash flow

7.2Risk sharing

7.3Alignment

7.4Existing rules

8What the evidence does and does not show

References

About this paper

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