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trial and error rather than true research." However, he refused to
concede that this project did not qualify. Elsewhere, Dr.
McDermott appeared to regard as significant the use of the arcane
report writer language of the Cyborg payroll system, as well as the
"heroic efforts" of NTS to sustain this "increasingly inadequate"
system.
Dr. Davis classified the task of maintaining and enhancing the
payroll system as "one of the oldest and most familiar in
information technology". He found that everything performed by NTS
was routine and well within industry practice.
Mr. Teixeira also found NTS' efforts entirely routine and
noted that the functionality added to Cyborg already existed at
every other major U.S. bank.
The Cyborg payroll system activities clearly do not fall
within the realm of qualified research. Dr. McDermott stated that
the key issue "was how long the system could be made to survive".
Cyborg was an outdated system. It is evident that the goal of NTS
was not to advance the principles of computer science, but rather
was to maintain a 1970's system running into the early 1990's. It
was this type of activity that Congress had in mind when it sought
to narrow the definition of qualified research and expressed its
concern that taxpayers were claiming the R&E credit even though
they were not engaged in high technology activities. See S. Rept.
99-313, at 694-695 (1986), 1986-3 C.B. (Vol. 3) 1, 694-695; H.
Rept. 99-426, at 178 (1985), 1986-3 C.B. (Vol. 2) 1, 178. Heroic
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