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).Page: 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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