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Petitioner interprets this language to mean that Congress
expected and directed that all expansion costs for an existing
trade or business are currently deductible. We do not agree with
petitioner's reading of this legislative history. Congress was
simply recognizing that if an expenditure was currently
deductible, section 195 did not change the characterization of
the expenditure if it was paid or incurred in connection with the
expansion of an existing business. Thus, Congress was
distinguishing these expenditures from those paid or incurred in
the creation or acquisition of a new trade or business to which
section 195 did apply. H. Rept. 96-1278, supra at 11, 1980-2
C.B. at 712-713 ("The determination of whether there is an
expansion of an existing trade or business or a creation or
acquisition of a new trade or business is to be based on the
facts and circumstances of each case as under present law.")
In NCNB Corp. v. United States, 684 F.2d at 291, the court
found the enactment of section 195 was "another indication that
the expenditures in question [were] current expenses rather than
capital costs". Relying on the definition of "investigatory
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