FMR Corp. and Subsidiaries - Page 41

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               We recognize that capitalization is not required for every             
          cost that produces any future benefit.  However, we do not agree            
          with petitioner's proposition that the claimed purpose of the               
          expenditures--to protect, promote, or expand its existing                   
          business--is controlling.  Rather than attempting to assign the             
          expenditures to a specific classification, such as expansion                
          costs, we believe that the more important question is whether the           
          expenditures in issue provide a significant future benefit to               
          petitioner.                                                                 
               Finally, petitioner argues that the legislative history of             
          section 195 supports its position that the expenditures here do             
          not create the "type" of future benefit that must be capitalized.           
          Petitioner contends that Congress explicitly recognized the                 
          current deductibility of the costs of expanding an existing trade           
          or business when it enacted section 195 to deal with the costs of           
          starting a new trade or business.  Section 195 was enacted by the           
          Miscellaneous Revenue Act of 1980, Pub. L. 96-605, sec. 102(a),             
          94 Stat. 3522, and was amended by the Deficit Reduction Act of              
          1984, Pub. L. 98-369, sec. 94(a), 98 Stat. 614.  Section 195, as            
          originally enacted in 1980, defined "startup expenditure" to mean           
          any amount                                                                  

               (1) paid or incurred in connection with--                              
                    (A) investigating the creation or acquisition of an               
                    active trade or business, or                                      
                    (B) creating an active trade or business, and                     




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