Norwest Corporation and Subsidiaries - Page 1

                                   110 T.C. No. 34                                    

                               UNITED STATES TAX COURT                                

                 NORWEST CORPORATION AND SUBSIDIARIES, Petitioner v.                  
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket Nos. 13908-92, 20567-93,        Filed June 29, 1998.            

                    Between 1986 and 1991, N, a bank holding company                  
               whose affiliates provide banking and other financial                   
               services, developed or modified previously developed                   
               software for the internal management and administration                
               of its businesses (internal use software).  N seeks tax                
               credits for increasing research activities pursuant to                 
               sec. 41, I.R.C., with respect to expenditures associated               
               with the development of its internal use software.  The                
               parties selected 8 of 67 internal use software activities              
               to serve as representative or sample activities to                     
               determine whether all or part of the 67 activities                     
               constituted qualified research for purposes of the tax                 

               1    These cases are consolidated for trial, briefing, and             
          opinion solely with respect to the issue of whether petitioner's            
          activities constitute qualified research pursuant to sec. 41,               
          I.R.C. (the research and experimentation credit, or R&E credit).            

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