Norwest Corp. v. Comm'r
United States Tax Court
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…
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