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.
26213-93.1
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
credit.
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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