PNC Bancorp, Inc. Successor to First National Pennsylvania Corporation, et al. - Page 35

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          activity, which included, among other things, securing potential            
          leases, reviewing the lessee's application, checking the lessee's           
          credit and trade references, and drafting lease documents.  Id.             
          We held that such expenditures were capital expenditures, because           
          "they secure for the partnerships the right to receive benefits             
          under each lease that last well beyond the taxable year of the              
          expenditure."  Id.                                                          
               Costs associated with the origination of the loans                     
          contribute to the generation of interest income and provide a               
          long-term benefit that the banks realize over the lives of the              
          underlying loans.  The resulting stream of income extends well              
          beyond the year in which the costs were incurred.  It was this              
          income benefit that was the primary purpose for incurring these             
          expenditures.23  While the useful life of a credit report and               
          other financial data may be of short duration, the useful life of           
          the asset they serve to create is not.  Therefore, like the                 
          appraisal costs in Woodward v. Commissioner, supra, and United              
          States v. Hilton Hotels Corp., supra, the construction-related              
          depreciation in Commissioner v. Idaho Power Co., supra, and the             
          lease acquisition costs in Strouth v. Commissioner, supra, the              


               23Petitioner argues that because the banks used the loan               
          application process as an opportunity to sell other services and            
          products, the costs associated with that function are not capital           
          expenses.  Petitioner does not attempt to define which costs are            
          related to loan origination and which are related to other                  
          selling costs.  However, SFAS 91, par. 6 provides that the direct           
          loan origination costs consist only of those costs related to               
          activities "that would not have been incurred but for that loan."           
          (Emphasis added.)  Therefore, by definition, the costs at issue             
          do not include additional selling expenses.                                 


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