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Software Taxation Expert Witness Capabilities

Mr. Wayne B. Norris, our Principal, was asked by the Internal Revenue Service to be the US Government's expert witness for software development issues in the multi-year case of Microsoft Corporation versus Commissioner of Internal Revenue [US Tax Court Docket Number 16878-96], the largest tax case of any kind ever litigated by any jurisdiction in history.  Mr. Norris authored four expert witness reports that were admitted into the record, and testified for approximately 7 hours, including voire dire, direct, cross, redirect, and recross.  Mr. Norris was the principal architect of the Government's technical approach toward interpretation of IRC 927(c) in the case of software taxation.  The Government won the case, and Mr. Norris's arguments were incorporated into the Court's opinion.  Upon qualified request, any or all of the expert witness reports and a transcript of the full testimony will be provided for examination.

Mr. Norris specialized in explaining very complex issues to the Court and attorneys in accessible language and in advising IRS attorneys on their strategies for the examination of Microsoft expert witnesses.

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One of the other senior expert witnesses in the case, Mr. Ray Ocampo, has agreed to provide his highest recommendation for Mr. Norris's work, upon qualified request.  Mr. Ocampo, who was the Government's witness for Intellectual Property, was the former Senior Vice President and Chief Counsel for Oracle Corporation for over 10 years, and is currently on the  Board of Directors of several firms.  Mr. Ocampo is currently Executive Director of the Berkeley Center for Law & Technology, University of California at Berkeley. (

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