Why Interviews Aren’t Enough: How to Build an R&D Documentation Strategy That Holds Up

Many tax teams still rely on interviews to gather details for R&D tax credit claims. While interviews can provide helpful context, they’re not enough to meet IRS expectations, especially under the new Form 6765 requirements.

The IRS has made it clear: they want real documentation. Interview notes might support a claim, but they can’t stand in for missing evidence.

To remain competitive—and compliant—your documentation must move beyond anecdotal knowledge and into structured, repeatable evidence that proves research activities as they occur.

Here’s how to evolve your documentation process so it actually holds up under scrutiny.

What the IRS Really Wants to See

IRS agents are looking for contemporaneous documentation—evidence created as the work happened.

Examples include:

• Design specs and engineering drawings
• Test protocols and results
• Jira or Confluence entries with time-stamped activity logs
• Emails or reports discussing technical challenges and solutions
• Project timelines showing iterations, decisions, and technical reviews

This type of documentation provides a credible, third-party-verifiable audit trail that aligns directly with the IRS’s four-part test.

The Risk of an Interview-Only Approach

Tax teams that rely solely on SME interviews often encounter:

• Inconsistencies between what’s said and what exists in documentation
• Generic or vague project descriptions that fail to demonstrate uncertainty or experimentation
• Missing links to cost centers or business components, which weakens the QRE calculation

Worse, it creates one more dependency that has to be refreshed year after year—without improving audit defensibility or operational efficiency.

What a Strong Documentation Strategy Looks Like

• Real-time capture: Encourage engineering and project teams to save documentation as they go, rather than retroactively summarizing activities months later.
• System integration: Pull evidence from tools teams already use—Slack, Teams, Jira, Google Docs, CAD platforms, or project lifecycle trackers like Monday.com or Asana.
• Mapped to Form 6765: Organize and tag documentation by business component and tie each item to IRS criteria: technical uncertainty, hypothesis, testing, and results.
• SME augmentation, not dependence: Use interviews only to fill in gaps or validate unclear areas—not as the sole basis for documentation.

Start With a Framework

If you’re looking to overhaul your documentation strategy, start with a simple question: What would an IRS examiner want to see without asking?

Then:

• Create folders by business component or R&D project that reflect your QRE allocations
• Populate them with evidence aligned to the four-part test, collected as projects progress
• Annotate where necessary to explain unclear references or acronyms
• Track what’s missing—then use SMEs selectively to close the gaps

This approach not only supports your claim—it creates process discipline that scales year over year.

Final Thoughts: Proactive Beats Reactive

Waiting until claim season to gather documentation is a recipe for weak claims. Start early, automate what you can, and use interviews as a tool—not a crutch.

If you need to help SMEs contribute better documentation, start by identifying the friction: do they lack clarity on what to write? Do they understand what the IRS looks for? A short training session and example-based prompts can go a long way.

To structure your documentation by business component, take inventory of your R&D efforts by product, feature, or process, then connect those to real artifacts—design docs, test results, dev notes—that map to Form 6765 requirements.

Want a checklist that walks through what good documentation looks like? Schedule a consultation with MASSIE today.

Jason Massie, CPA, Esq.

As the Founder and President of MASSIE R&D Tax Credits, Jason is responsible for the quality, consistency, and integrity of our services. His strategic vision and leadership drive innovation within the company, encouraging collaboration and ne...