- 2 - Mark Hager, Robert J. Jones, and Susan K. Matlow, for petitioner. Robert M. Ratchford and Robert M. Fowler, for respondent. HALPERN, Judge: Respondent determined the following deficiencies in petitioner's Federal income taxes: Year Deficiency 1983 $2,605,571 1984 2,442,134 1985 29,187 1986 19,301,530 Respondent also determined that the provision for increased interest under section 6621(c) applied for 1983, 1984, and 1986. Unless otherwise noted, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. After concessions by the parties and the continuation of other issues, the sole issue for decision is whether certain computer software expenditures made by petitioner during the years in issue qualify for the investment tax credit. Resolution of that issue depends on the characterization of the acquired software as either tangible or intangible property, as only investments in tangible property are eligible for the investment tax credit. We conclude that the acquired software is tangible personal property eligible for the investment tax credit.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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