National Data Corp. v. United States

OPINION

ALLEGRA, Judge.

For most of the period from 1962 through 1985, a taxpayer who acquired qualifying machinery and equipment for use in its trade or business was allowed an “investment tax credit” as a dollar-for-dollar offset against its income tax liability, in an amount equal to a specified percentage of its investment. The Tax Reform Act of 1986 (the Reform Act), Pub.L. No. 99-514, 100 Stat. 2085, generally *25eliminated this credit for property placed in service after December 31,1985. But, as tax acts are wont to do, the Reform Act contained transitional rules, among them an exception…