Publix Super Markets Inc. is suing the federal government to recover a $2.6 million research credit that the IRS disallowed for the 2018 tax year after determining that the company’s expenses did not qualify as research. (Publix Super Markets Inc. & Subsidiaries v. United States, No. 26-cv-2496, complaint filed 8/25/2026)

In a complaint filed August 25 in the U.S. District Court for the Middle District of Florida, the supermarket chain alleges the IRS erroneously denied the credit. Publix argues that its activities in developing in-house software and innovating its private-label food products met all statutory requirements for the Credit for Increasing Research Activities under IRC § 41.

The complaint alleges the IRS “applied incorrect legal standards and principles” in disallowing the credit.

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