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relating to internal use software development activities. H. Conf.
Rept. 99-841 (Vol. II), at II-73 through II-74 (1986), 1986-3 C.B.
(Vol. 4) 1, 73-74 (and as adopted by the Department of the Treasury
in its proposed regulations, section 1.41-4(e)(5), Proposed Income
Tax Regs., 62 Fed. Reg. 83 (Jan. 2, 1997)).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The
stipulation of facts and the attached exhibits are incorporated
herein by this reference.
Norwest Corporation, a Delaware corporation, is the common
parent of an affiliated group of corporations that timely filed
consolidated U.S. Corporation Income Tax Returns (Forms 1120) for
the years in issue. It is a bank holding company whose affiliates
provide banking and other financial services.
At the time the petitions were filed, Norwest Corporation had
its principal place of business in Minneapolis, Minnesota.
1. Background
During the years in issue, petitioner engaged in numerous
projects involving the development of internal use software--that
is, software developed solely for petitioner's internal business
and management purposes. Most of these projects were managed and
executed by Norwest Technical Services, Inc. (NTS or Norwest
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