The fair market value of custom software that a New Zealand company had developed to run its steel mill was found to have a fair market value equal to the amount shown in the New Zealand company's records as being the cost, plus a 70% adjustment factor to reflect the fact that most companies' tracking systems do not record between 30% and 70% of the real effort that goes into software. The capital cost to the taxpayer of the software was reduced from the purchase price to this amount.
Note
see also 2003 DTC 1545, 2003 TCC 544
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