Tax and Accounting Software Corp. v. United States

301 F.3d 1254 (2002)

Study Aids
Case Briefs Overview
Casebooks
Case Briefs
T
From our private database of 46,300+ case briefs, written and edited by humans—never with AI.

Tax and Accounting Software Corp. v. United States

United States Court of Appeals for the Tenth Circuit
301 F.3d 1254 (2002)

  • Written by Tammy Boggs, JD

Facts

Tax and Accounting Software Corporation (TAASC), an S Corporation, was in the business of developing and selling software for tax and accounting professionals. In 1993 and 1994, TAASC incurred research and development (R&D) expenses to make four computer-software products. The products were innovative in the sense that they uniquely allowed for financial data to be turned into financial statements and transferred for tax-preparation purposes in a manner that was convenient and desirable for professionals. TAASC did not doubt that the products could be developed, and the products were not technically difficult to develop. The owners of TAASC (the taxpayers) (plaintiffs) claimed a tax credit under 26 U.S.C. § 41 for the R&D expenses, but the Internal Revenue Service (IRS) (defendant) disallowed the credit. The taxpayers brought a refund suit, and the district court awarded summary judgment for TAASC. The government appealed, arguing that R&D expenditures for developing computer-software products did not meet the requirements for a tax credit insofar as the R&D was not undertaken to discover new information and did not involve a process of experimentation within the meaning of the statute.

Rule of Law

Issue

Holding and Reasoning (Lucero, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 824,000 law students since 2011. Some law schools even subscribe directly to Quimbee for all their law students.

    Unlock this case briefRead our student testimonials

  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

    Learn about our approachRead more about Quimbee

Here's why 824,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 46,300 briefs, keyed to 989 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 824,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 46,300 briefs - keyed to 989 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership

Casebooks

Intellectual Property

Key Terms