- 68 - discovery required by the taxpayer, noting the legislative history of section 41. On the other hand, petitioner contends that "expand or refine" is only illustrative and is intended to contrast the mere use of a computer which in and of itself does not necessarily involve fundamental reliance on the principles of computer science. We believe the purpose of the first sentence of note 3 ("Research does not rely on the principles of computer science merely because a computer is employed.") is to emphasize that Congress intended the R&E credit not for the use of the hard sciences per se, but for the use of the principles of the hard sciences in conducting research. "Principle" is defined as "a comprehensive and fundamental law, doctrine, or assumption". Webster's Ninth New Collegiate Dictionary (1985). Clearly, the use of a computer does not necessarily require reliance on any fundamental laws, doctrines, or assumptions. The purpose of the second sentence of note 3 ("Research may be treated as undertaken to discover information that is technological in nature, however, if the research is intended to expand or refine existing principles of computer science.") is to indicate that the taxpayer must discover information with respect to the principles of the hard sciences on which it fundamentally relies. Note 3 sets forth two means of discovering information about the principles of the hard sciences--either by "expanding", or by "refining"--eitherPage: Previous 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 Next
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