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NOTES 273 Tax Lawyer, Vol. 57, No. 1 NOTE NO RESEARCH AND DEVELOPMENT TAX CREDIT FOR COMMERCIAL SOFTWARE DEVELOPERS: TAX AND ACCOUNTING SOFTWARE CORP. V. UNITED STATES Software developers attempting to claim a tax credit for research and developmeen expenditures will face great difficulties due to a decision by the United States Court of Appeals for the Tenth Circuit. In Tax and Accounting Software Corp. v. United States,1 the court offered new guidelines for applying the “discovvery and “process...

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