§44F — Renumbered § 30]

The credit for increasing research activities that Congress enacted as section 44F was redesignated by Congress in 1984 as section 30 of the Code, Deficit Reduction Act of 1984, Pub.

d (3) qualified research to the extent funded by any grant, contract, or otherwise by another person (or any governmental entity). In TSR, Inc. & Sub. v. Commissioner, 96 T.C. 903 (1991), we considered a taxpayer’s claim to the R&E credit under then sec. 44F for 1981. The taxpayer, a manufacturer of historical and fantasy games, sought the credit for its historical research into the development of the games. In considering the taxpayer’s claim, we applied the plain meaning to the terms “experime