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          and to syndication expenses,16 none of which are currently                  
          deductible.  Secs. 248(a); 709(a).                                          
               Petitioner argues that the costs associated with these                 
          activities are not organization costs with regard to petitioner             
          because the costs do not relate to its capital structure and were           
          incurred solely to maintain and promote its investment management           
          business.  Nevertheless, much like the reorganization                       
          expenditures in E.I. du Pont de Nemours & Co. v. United States,             
          supra, we find that the costs incurred by petitioner here                   
          "resulted in a benefit to the taxpayer which could be expected to           
               16Sec. 1.709-2(a), Income Tax Regs., provides the following            
          examples of partnership organizational expenditures:                        
               Legal fees for services incident to the organization of                
               the partnership, such as negotiation and preparation of                
               a partnership agreement; accounting fees for services                  
               incident to the organization of the partnership; and                   
               filing fees.  * * *                                                    
               Sec. 1.709-2(b), Income Tax Regs., defines syndication                 
          expenses as follows:                                                        
               Syndication expenses are expenses connected with the                   
               issuing and marketing of interests in the partnership.                 
               Examples of syndication expenses are brokerage fees;                   
               registration fees; legal fees of the underwriter or                    
               placement agent and the issuer (the general partner or                 
               the partnership) for securities advice and for advice                  
               pertaining to the adequacy of tax disclosures in the                   
               prospectus or placement memorandum for securities law                  
               purposes; accounting fees for preparation of                           
               representations to be included in the offering                         
               materials; and printing costs of the prospectus,                       
               placement memorandum, and other selling and promotional                
               material.  * * *                                                       
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