For years, farmers were told the R&D credit was a tech-company thing. That was never true, and now there are court rulings that say so out loud. In 2022, the Tax Court ruled in JG Boswell Co. v. Commissioner that row-crop farming can qualify. In February 2026 it went further in George v. Commissioner, holding that the work a producer does to keep livestock healthier and growing better is real research under the tax law. The IRS argued the trials were just picking from options anyone could look up. The court disagreed.
Put those two cases together and the picture is clear. Whether you grow crops or raise animals, the experimenting you do to farm better can earn the same credit that manufacturers and engineers have claimed for decades.
The test does not care whether you grow corn or raise hogs. It cares whether you were working out the answer to a problem you did not already have solved. Most farms do this every season without ever calling it research. Here is the kind of work that tends to qualify:
| What you farm | Trials that often qualify |
|---|---|
| Row crops | New seed varieties, planting density and timing trials, cover crops and no-till, and changes to your fertilizer or soil program. |
| Livestock | Feed and ration trials, breeding and genetics work, vaccine and probiotic trials, and disease-prevention protocols. |
| Dairy | Ration changes to lift milk yield, automated or robotic milking, and herd-health and breeding programs. |
| Irrigation & equipment | New irrigation or drainage setups, precision-ag and GPS systems, and equipment you modify or build to fit your ground. |
| Land & resources | Work to cut water use, manage manure and nutrients, or build up soil health over time. |
Notice the common thread. None of it is routine. Planting the same seed the same way you did last year is not research. Testing a new variety to see whether it yields better on your ground is. The credit rewards the trying, not the winning.
Once an activity qualifies, you add up the costs tied to it. For a farm, that usually comes down to three things:
Here is where farms get tripped up. In the George case, the court agreed the livestock work qualified, then threw out part of the claim because the records were too thin to back it up. That is the whole lesson in one ruling. The credit is real, but it is not a handshake. You have to show your work.
You do not need a research department to do that. You need decent notes, kept during the season, that capture three things:
Notes you write while the trial is happening beat anything you try to reconstruct a year later, when the IRS is the one asking.
The credit goes on Form 6765 with your tax return. If you have run trials in past seasons and never claimed it, you can usually go back and amend a few years of returns to catch up. The mechanics work the same for a farm as for any other business, and we walk through them in the main R&D tax credit guide.
No. Improving what you already grow or raise counts. Testing a new fertilizer program on the same crop, or a new ration for the same herd, is exactly the kind of work the credit is built for.
It still counts. The credit rewards the attempt to solve a problem, not the result. A variety trial that yielded worse, or a feed change that did not pan out, can qualify the same as one that succeeded.
No. There is no size minimum. Smaller farms are often the ones leaving the most on the table, because no one ever told them the work qualifies.
No, they are two different things. The R&D credit is for the experimenting you do. Section 180 is a deduction for the leftover fertilizer in farmland you bought. Plenty of farms qualify for both.
Claiming what you genuinely earned, with records to back it up, is not the problem. Inflated or undocumented claims are. The court cases show farms win when the work qualifies and the paperwork holds up, and lose ground when it does not.
This guide is general information, not tax advice. Your situation has its own facts, so talk to a credentialed professional before you act on anything here.