Norwest Corporation and Subsidiaries - Page 92

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          the tests relate to the discovery of different information.                 
          Finally, we note that the legislative history of section 41 reveals         
          that in 1986, Congress sought to tighten the requirements for               
          obtaining the R&E credit because taxpayers were not using the               
          credit for high technology purposes.  H. Rept. 99-426, at 178               
          (1985), 1986-3 C.B. (Vol. 2) 1, 178; S. Rept. 99-313, at 694                
          (1986), 1986-3 C.B. (Vol. 3) 1, 694-695.  Congress effectuated this         
          goal by adding three tests to section 41, including the discovery           
          test, but did not change the meaning of section 174 (and presumably         
          the discovery test subsequently created under the section 174               
          regulations).  H. Conf. Rept. 99-841 (Vol. II), supra at II-76,             
          1986-3 C.B. (Vol. 4) at 71, 76; see also S. Rept. 97-144, at 81             
          (1981), 1981-2 C.B. 412, 441.  We therefore conclude that Congress          
          intended to treat the discovery test under section 41 more narrowly         
          than the discovery test created under section 174.                          
               The dictionary definition of "discover" is "to make known or           
          visible" or "to obtain sight or knowledge of for the first time".           
          Webster's Ninth New Collegiate Dictionary (1985).  The legislative          
          history of section 41 dictates that the knowledge gained from the           
          research and experimentation must be that which exceeds what is             
          known in the field in which the taxpayer is performing the research         
          and experimentation--in this case, the computer science field.  The         
          fact that the information is new to the taxpayer, but not new to            







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