Legal Opinion

Norwest Corp. v. Comm'r

United States Tax Court

Decided June 29, 1998No. Tax Ct. Dkt. No. 13908-92; Docket Nos. 20567-93, 26213-93PublishedCited by 20 opinions

Between 1986 and 1991, N, a bank holding company whose affiliates provide banking and other financial services, developed or modified previously developed software for the internal management and administration of its businesses (internal use software). N seeks tax credits for increasing research activities pursuant to sec. 41, I.R.C., with respect to expenditures associated with the development of its internal use software.

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Between 1986 and 1991, N, a bank holding company whose affiliates provide banking and other financial services, developed or modified previously developed software for the internal management and administration of its businesses (internal use software). N seeks tax credits for increasing research activities pursuant to sec. 41, I.R.C., with respect to expenditures associated with the development of its internal use software. The parties selected 8 of 67 internal use software activities to serve as representative or sample activities to determine whether all or part of the 67 activities…

1Opinion of the Court

CONTENTS

Page

FINDINGS OF FACT. 458

1. Background. 458

2. Software Development Methodology . 458

A. Phase 1: Request. 459

B. Phase 2: Project Initiation . 459

C. Phase 3: Definition . 459

D. Phase 4: Logical Design . 460

E. Phase 5: Physical Design . 460

F. Phase 6: Development . 460

G. Phase 7: Testing . 460

H. Phase 8: Implementation . 461

I. Phase 9: Postimplementation . 461

J. Application of the Software Development Methodology. 461

3. The Eight Sample Internal Use Software Development Activities . 462

A. Strategic Banking System. 463

B. Trust TU. 467

C. Success... 470

D. General Ledger . 473

E. Money…

2Cases cited28 opinions

  1. Landgraf v. USI Film ProductsSupreme Court of the United States · 1994
  2. United States v. American Trucking AssociationsSupreme Court of the United States · 1940
  3. Interstate Transit Lines v. CommissionerSupreme Court of the United States · 1943
  4. Buffalo Tool & Die Mfg. Co. v. CommissionerUnited States Tax Court · 1980
  5. Seymour Silverman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976

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3Cited by20 opinions

  1. Universal Instruments Corp. v. Micro Sys. Eng'g, Inc.Court of Appeals for the Second Circuit · 2019
  2. United States v. McFerrinCourt of Appeals for the Fifth Circuit · 2009
  3. Tax & Accounting Software Corp. v. United StatesCourt of Appeals for the Tenth Circuit · 2002
  4. TG Mo. Corp. v. Comm'rUnited States Tax Court · 2009
  5. Wicor, Inc. v. United StatesCourt of Appeals for the Seventh Circuit · 2001

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