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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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