FMR Corp. and Subsidiaries - Page 42

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               (2) which, if paid or incurred in connection with the                  
               expansion of an existing trade or business (in the same                
               field as the trade or business referred to in paragraph                
               (1)), would be allowable as a deduction for the taxable year           
               in which paid or incurred.[18]  [Emphasis added.]                      

          Petitioner claims that the legislative history accompanying the             
          1980 enactment of section 195 confirms that Congress explicitly             
          recognized that business expansion costs are currently                      
          deductible:                                                                 

                    In the case of an existing business, eligible                     
               startup expenditures do not include deductible ordinary                
               and necessary business expenses paid or incurred in                    
               connection with an expansion of the business.  As under                
               present law, these expenses will continue to be                        
               currently deductible.  * * * [H. Rept. 96-1278, at 11                  
               (1980), 1980-2 C.B. 709, 712; emphasis added.]                         





               18Sec. 195(c), as amended, defines startup expenditure to              
          mean any amount--                                                           
               (A) paid or incurred in connection with--                              
                    (i) investigating the creation or acquisition of an               
                    active trade or business, or                                      
                    (ii) creating an active trade or business, or                     
                    (iii) any activity engaged in for profit and for the              
                    production of income before the day on which the active           
                    trade or business begins, in anticipation of such                 
                    activity becoming an active trade or business, and                
               (B) which, if paid or incurred in connection with the                  
               operation of an existing active trade or business (in the              
               same field as the trade or business referred to in                     
               subparagraph (A)), would be allowable as a deduction for the           
               taxable year in which paid or incurred.                                




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