Contemporaneous Documentation Requirements

In the context of R&D tax credits, "contemporaneous documentation" means records created at or near the time the research activity was performed — not reconstructed months or years later.

Records created while work is happening can preserve context for a later review. The governing question remains whether the taxpayer retains records in usable form and detail to substantiate the claimed expenses.

During a claim review, the taxpayer may need evidence that:

1. Activities actually occurred as described
2. The four-part test was met at the time of the activity (not rationalized later)
3. Time allocation between qualifying and non-qualifying work is substantiated
4. Expenses tie back to specific qualifying activities

After-the-fact explanations may be harder to evaluate when the underlying project records are missing. Keep the original activity and financial records wherever practical.

For software development teams, the strongest contemporaneous evidence includes:

• Version control history: Git commits, branches, and pull requests — timestamped, attributed, and descriptive
• Time tracking data: Per-project time allocation captured as work happens
• Design and architecture documents: Created at project inception, showing the uncertainty that existed
• Code review records: Comments and feedback showing technical evaluation
• Sprint/project management records: Tickets, stories, and task descriptions
• AI-tool metadata: Session timing or project context when available, paired with records that explain the underlying work
• Test results and benchmarks: Evidence of experimentation and evaluation

The key principle: if it was created while the work was happening, it's contemporaneous. If it was created during tax season, it's reconstruction.

Software teams may already have useful records across GitHub, Jira, Slack, local editors, and AI tools. The practical challenge is to:

1. Organizing existing records to map to IRS criteria
2. Classifying each activity against the four-part test
3. Calculating time allocation from activity data
4. Generating the narratives and forms the IRS expects

The support file should preserve the connection between business components, technical work, expense records, and any decisions or exclusions that need professional review.

QuarryFi organizes connected development metadata, project context, and review decisions into CPA-reviewable support materials. It does not treat every commit or AI-assisted session as qualifying research, and it does not replace the taxpayer's recordkeeping or final professional review.