Charles Medallis (KPMG) & Leonard "Jay" Hite (KPMG) have posted Union Carbide: Good News and Guidance on the Research Credit, 125 Tax Notes 213 (Oct. 12, 2009), on SSRN.  Here is the abstract:

This article suggests that the news may actually be good for taxpayers that engage in manufacturing process research, including those companies that must conduct experimental trial runs as part of their process of experimentation. The article makes observations regarding the court’s analyses and conclusions on several contentious issues that have arisen in recent research credit controversies between taxpayers and the IRS, and it concludes with some industry specific observations on the application of the court’s analyses.