(August 27, 2018, 9:12 AM EDT) -- WASHINGTON, D.C. — A June 22 memorandum from the Office of the Chief Counsel of the Internal Revenue Service stated that a franchisor must use the separately stated prices in a software license agreement with franchisees to differentiate gross receipts attributable to Domestic Production Gross Receipts (DPGR) and gross receipts that do not qualify as DPGR because the information is readily available....