TSR, Inc. v. Commissioner
United States Tax Court
P manufactured and sold games and game-related products. In developing the games, P conducted research on the various topics which formed the basis of the games. The information derived from the research was incorporated into the mechanics of the particular game. P also "play tested" the game prototype to determine if the game had any unintended results and to make adjustments designed to enhance the entertainment value of the game.
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P manufactured and sold games and game-related products. In developing the games, P conducted research on the various topics which formed the basis of the games. The information derived from the research was incorporated into the mechanics of the particular game. P also "play tested" the game prototype to determine if the game had any unintended results and to make adjustments designed to enhance the entertainment value of the game. Held: The sec. 44F credit only applies to research that is scientific or technological in nature. Research and game development conducted by P is not scientific…
1Opinion of the Court
RUWE, Judge:
In his notice of deficiency, respondent determined the following deficiencies in petitioner’s Federal corporate income tax:
TYE Deficiency
Sept. 30, 1977 $12,249
Sept. 30, 1978 5,905
Sept. 30, 1979 291
Sept. 30, 1980 89,711
June 30, 1981. 681,471
June 30, 1982. 481,176
The deficiencies at issue for petitioner’s taxable years ending September 30, 1977, 1978, and 1979, result from respondent’s disallowance of tentatively allowed refunds caused by carrybacks of unused tax credits from petitioner’s fiscal year ending September 30, 1980. The deficiency at issue for petitioner’s taxable year…
2Cases cited4 opinions
- Commissioner v. BrownSupreme Court of the United States · 1965
- Bell v. New JerseySupreme Court of the United States · 1983
- Regan v. WaldSupreme Court of the United States · 1984
- Home Group, Inc. v. CommissionerCourt of Appeals for the Second Circuit · 1989
3Cited by14 opinions
- Norwest Corp. v. Comm'rUnited States Tax Court · 1998
- United Stationers, Inc. v. United StatesCourt of Appeals for the Seventh Circuit · 1999
- United Stationers, Inc. v. United StatesDistrict Court, N.D. Illinois · 1997
- Microsoft Corp. v. CommissionerUnited States Tax Court · 2000
- Fudim v. CommissionerUnited States Tax Court · 1994
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