Internal-Use Software Case Law Seems Set

I enjoyed the authors’ discussion of the issues and the judicial and administrative pronouncements cited in “Internal-Use Software and the Research Credit” ( JofA , Dec.99, page 79). However, the authors might also have noted that the U.S. Supreme Court did not grant certiorari in the United Stationers case (June 21, 1999). The Seventh Circuit had previously upheld the district court. Therefore, the case law, for the time being, seems settled and congruent with the regulations.

Jack Norman
Arlington, Virginia