The U.S. Tax Court has issued its decision in the case of Adams Challenge (UK) Limited v. Commissioner of Internal Revenue. The case concerns claims by the UK company for deductions and credits with respect to income earned in connection with a U.S. trade or business by the UK company for 2009 and 2010. For the years concerned, the UK company did not file Federal income tax returns until February 2017, which was more than two years after the IRS had prepared substitute returns and issued a notice of deficiency. Because the returns had not been filed until after the...