Norwest Corporation and Subsidiaries - Page 98

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          the use of a structured process of experimentation through the              
          continuous development of hypotheses that require testing and               
          analysis until the method for reaching the objective is discovered.         
          Congress did not specify that any particular number of hypotheses           
          be developed by the taxpayer, but the more hypotheses that are              
          developed, tested, and analyzed, the more likely the project will           
          satisfy the process of experimentation test.                                
               This test also requires that "substantially all" of the                
          activities constitute elements of a process of experimentation.             
          This requirement raises two questions: (1) What does the term               
          "substantially all" mean? and (2) what activities come within the           
          elements of a process of experimentation?                                   
               Respondent contends that "substantially all" means at least 80         
          percent, referring to section 1.41-2(d)(2), Income Tax Regs., which         
          defines the term "substantially all" with respect to qualified              
          wages under section 41 as meaning at least 80 percent of the wages          
          paid or incurred by the taxpayer for the employee.  Petitioner does         
          not dispute respondent's proposed 80-percent test.                          
               We agree with respondent and hold that in the context of               
          section 41, the term "substantially all" refers to at least 80              
          percent of the activities that constitute elements of a process of          
          experimentation. This interpretation is consistent with the                 








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