As stated in Matter of the Petition of Nerac, Inc. (N.Y. Div. Tax App., DLJ. Dkt. Nos. 822568 and 822651, 7/15/2010), Nerac was a research and advisory firm which provides technical, scientific, and engineering research to its clients. Nerac employed scientists, engineers, and other professionals with the most relevant experience and expertise to address clients’ specific questions and to hone the characteristics of the client’s problem and develop a search strategy. The analyst identified the most helpful databases and other information resources—both public domain databases and proprietary databases—and then implemented the specialized research strategy to answer the client’s question. The analyst ultimately provided the client with a unique
