PNC Bancorp, Inc. Successor to First National Pennsylvania Corporation, et al. - Page 41

                                         41                                           
          Commissioner, 503 U.S. at 84 (quoting Deputy v. du Pont, 308 U.S.           
          at 493).  The fact that Congress has not chosen to act in this              
          area has no special relevance in these cases.                               

          Conclusion                                                                  

               We have found that the expenditures at issue were incurred             
          in creating loans that were separate and distinct assets.  We               
          hold that the banks were not entitled to deduct these                       
          expenditures under section 162(a).  Rather, they are to be                  
          capitalized under section 263(a) and recovered through                      
          amortization.                                                               


                                                  Decisions will be entered           
                                             under Rule 155.                          

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