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debit card system. Although these changes were relatively minor in
comparison to the process of connecting the Visanet module to the
Base 24 system, they still required a pattern of trial and error
through testing and retesting. Further, because the debit card
operated on the same system that operated the ATM card, it was
important for the various Norwest systems to recognize that the
debit card was a distinct product.
Ultimately, the debit card went into production and
implementation in January 1990, as scheduled. Norwest entered the
market with the debit card approximately 3 months ahead of its
nearest competitor, First Bank.
OPINION
Our task herein is to determine whether any or all of the
eight sample internal use software development activities of
Norwest constitute qualified research for purposes of the tax
credit provided by section 41. The parties agree that section 41
and its legislative history, combined, set forth seven tests to
determine whether internal use software development activities
constitute qualified research.
This is a case of first impression in this Court. However, we
are mindful of the recent decision of the District Court for the
Northern District of Illinois in United Stationers, Inc. v. United
States, 982 F. Supp. 1279 (N.D. Ill. 1997), on appeal (7th Cir.,
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