- 13 - III. Analysis We note at the outset that petitioners’ reconstruction of qualifying expenses was unreliable, inaccurate, incomplete, and wholly insufficient to establish what various workers did and whether such expenses qualify for the research credit. In addition, petitioners failed to have their computer expert address technical issues relevant to the case, and, as noted below, the testimony of petitioners’ witnesses further supports our conclusion that work performed by Applied Systems’ employees, during the years in issue, does not qualify for the research credit. A. TAM Most of the product development of the TAM module occurred during 1980 through 1989. In describing a “sophisticated approach” that Applied Systems had “invented” and used in the TAM module, petitioners’ programmer testified: “This would have been in the ‘80s.” During the years in issue, employees merely updated the TAM module. Solutions to problems of rounding numbers, locking transactions, and expanding representation were commonly known in the computer science field and did not present significant programming challenges. Applied Systems’ purchase and use of third-party software to facilitate managing memory, multitasking, and indexing tasks indicates that these techniques were also known in the computer science field. Petitioners’Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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