Norwest Corporation and Subsidiaries - Page 24

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               To summarize, we conclude that all expenses paid or incurred           
          by Norwest in the development of the SBS customer module constitute         
          qualified research through the first deployment of the customer             
          module to each of Norwest's banks, and that expenses relating to            
          customization activities by Norwest after receipt of the first SBS          
          release do not.                                                             
               B.  Trust TU                                                           
               Dr. McDermott found that the NTS staff used "considerable              
          ingenuity" in keeping the Trust TU system running as long as                
          possible.  He stated that even though the project was eventually            
          abandoned, had Norwest's Trust TU system failed before new                  
          technology (the Compass system) was available, Norwest would have           
          incurred significantly  greater  costs  in  running  its  trust             
          department.  Thus, he concluded that the project was a "mixed               
          success".                                                                   
               Dr. Davis characterized this project generally as maintenance          
          and enhancement of the source code and claimed that the efforts to          
          increase volume and efficiency were "one of the most common,                
          routine tasks in information processing".  He found that the                
          volumes sought by NTS were well within the then state of the art.           
               Mr. Teixeira also characterized the Trust TU project as                
          generally maintenance and enhancement efforts.  He found that the           
          changes did not add any new functionality that was not already              
          available at any other trust department.  In this regard, he noted          
          that the volume sought by NTS was well below the volume already             



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