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expense, deductible under � 162(a) in the absence of
other factors not established here. * * *
In INDOPCO, Inc. v. Commissioner, supra at 86, the Supreme Court
explained that "Lincoln Savings stands for the simple proposition
that a taxpayer's expenditure that 'serves to create or enhance *
* * a separate and distinct' asset should be capitalized under �
263."
Petitioner does not argue that the loans are not separate
and distinct assets of the banks. Clearly they are. Rather,
petitioner argues that there are "other factors" present which
allow deductibility of the loan origination costs. The factors
upon which petitioner relies are that the type of costs in issue
are incurred every day in the banking business, they are integral
to the day-to-day banking operations of the banks, and they
provide only short-term benefits. Petitioner concludes that the
"every-day, recurring costs" at issue are currently deductible
under section 162(a).
Recurring Expenses
Relying on Iowa-Des Moines Natl. Bank v. Commissioner, 68
T.C. 872 (1977), affd. 592 F.2d 433 (8th Cir. 1979); Colorado
Springs Natl. Bank v. United States, 505 F.2d 1185 (10th Cir.
1974); and First Natl. Bank of South Carolina v. United States,
558 F.2d 721 (4th Cir. 1977), petitioner asserts that credit
evaluation and recordkeeping costs, such as those at issue here,
are currently deductible and not required to be capitalized under
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