C.C.M. 201313020 (Nov. 30, 2011)

(taxpayer publishes books and printed materials; taxpayer conducts market research, resource planning, content and layout development and editing which allows for the creation of electronic version of book; taxpayer uses contract manufacturers to produce books in mass; issue is whether taxpayer is eligible for the domestic production deduction of I.R.C. Sec. 199 for its activities; IRS concluded that while contract manufacturer's activities constitute the MPGE of QPP, taxpayer's activities related to producing electronic version of book do not result in QPP because it involves the production of an intangible asset that is not QPP; print specification activities are non-MPGE activities; related packaging activities are not MPGE of QPP because other activities are not qualified activities).