Norwest Corporation and Subsidiaries - Page 96

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               experimentation.)  The conference agreement also provides              
               that research relating to style, taste, cosmetic, or                   
               seasonal design factors is not treated as conducted for                
               a functional purpose and hence is not eligible for the                 
               credit.                                                                
          H. Conf. Rept. 99-841 (Vol. II), supra at II-72, 1986-3 C.B. (Vol.          
          4) at 72.                                                                   
               The parties do not seriously dispute the meaning of the                
          business component test or the legislative history.  Indeed, it is          
          evident that Congress intended only that the taxpayer's activities          
          provide some level of functional improvement, at a minimum.                 
               D.  The Process of Experimentation Test                                
               The process of experimentation test requires that                      
          substantially all of the activities which constitute elements of a          
          process of experimentation relate to a new or improved function,            
          performance, reliability, or quality. The process of                        
          experimentation test, which is referenced in the discovery test, is         
          explained by Congress as follows:                                           
                    The term process of experimentation means a process               
               involving the evaluation of more than one alternative                  
               designed to achieve a result where the means of achieving              
               that result is uncertain at the outset.  This may involve              
               developing one or more hypotheses, testing and analyzing               
               those hypotheses (through, for example, modeling or                    
               simulation), and refining or discarding the hypotheses as              
               part of a sequential design process to develop the                     
               overall component.                                                     
                    Thus, for example, costs of developing a new or                   
               improved business component are not eligible for the                   
               credit if the method of reaching the desired objective                 
               (the new or improved product characteristics) is readily               






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