- 100 - In both the Davis and Teixeira reports, it appears that respondent's experts found that Norwest was not engaged in qualified research in the SBS project because the majority of the work was performed by EDS. This is only relevant, however, if EDS was not performing contract research on behalf of Norwest. Respondent contends that EDS did not perform contract research. We find that together Norwest and EDS engaged in qualified research in the SBS project with respect to the customer module. See sec. 1.41-2(e)(5), Examples (5) and (6), Income Tax Regs. (allowing R&E credit where in-house and contract research are performed together).62 In making this finding, we are influenced by the writings of respondent's expert, the Tower Group, which were prepared before its involvement in this case and are a part of the record. The SBS project was a massive effort at developing an integrated banking system that could interact with several other systems and handle a tremendous volume of data. Although some integrated systems existed in 1986 (about 25 percent of the top 100 U.S. banks had such systems according to Mr. Teixeira), none of them could handle the volume of data in the SBS system, nor were they customer based (rather, they were product or account based). 62 Although petitioner claimed that it was a "development partner" with EDS in the development of the SBS system, neither petitioner nor respondent suggests that Norwest and EDS were engaged in a partnership that would implicate the rules under sec. 1.41-2(a)(4), Income Tax Regs.Page: Previous 90 91 92 93 94 95 96 97 98 99 100 101 102 103 104 105 106 107 108 109 Next
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