1. Whether, under a proper application of law, an administrative agency finding should be given the presumption of correctness when it is uncontroverted that the agency conducted no independent review prior to filing a lawsuit against a taxpayer, such that a Court applies such a presumption resulting in the Grigsbys being prohibited from presenting their evidence, which included both documents and testimony, to the triers of fact.

2. Whether the petitioners had the burden of proof on summary judgment motion despite the government being both plaintiff and the movant.

3. Whether the existence of a fixed fee contract to deliver a flood control structure, constituted a payment for research activities or an end product.

Whether an administrative agency finding should be presumed correct when the agency conducted no independent review prior to filing suit