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The Internal Revenue Service is more aggressively challenging claims bysoftware companies for research credits for software development. Armed withtwo favorable court decisions on credit claims for “internal-use” software(developed primarily for internal use rather than sale), the IRS has adopteda parsimonious stance for all research credit claims – not just claims basedon internal-use software research. On Dec. 2, 1998, the IRS issuedcontroversial proposed regulations that echo the language in thesedecisions.

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