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NOTES 403 Tax Lawyer, Vol. 54, No. 2 NOTE RESEARCH TAX CREDIT CAN APPLY TO SOFTWARE DEVELOPMENT AS CONGRESS INTENDED: TAX AND ACCOUNTING SOFTWARE CORP. V. UNITED STATES In Tax and Accounting Software Corp. v. United States, the United States District Court for the Northern District of Oklahoma held that development of a software program not yet available to the public or members of the computer science field, constituted qualified research for purposes of the research and expenditure tax credit...