Norwest Corporation and Subsidiaries - Page 2

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               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.                   






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