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expense, (4) incurred during the taxable year, and (5) made to
carry on a trade or business. See Commissioner v. Lincoln Sav. &
Loan Association, 403 U.S. 345 (1971); see also Rule 142(a);
INDOPCO, Inc. v. Commissioner, supra at 86; Welch v. Helvering,
290 U.S. 111, 114-116 (1933). An expense that creates a separate
and distinct asset is not "ordinary". See Commissioner v.
Lincoln Sav. & Loan Association, supra at 354; see also FMR Corp.
& Subs. v. Commissioner, 110 T.C. 402, 417 (1998); PNC Bancorp,
Inc. v. Commissioner, 110 T.C. 349 (1998); Iowa-Des Moines Natl.
Bank v. Commissioner, 68 T.C. 872, 878 (1977), affd. 592 F.2d 433
(8th Cir. 1979). Nor is an expense "ordinary" when it generates
a significant long-term benefit that extends beyond the end of
the taxable year. See INDOPCO, Inc. v. Commissioner, supra at
87-88; United States v. Mississippi Chem. Corp., 405 U.S. 298,
310 (1972); Central Tex. Sav. & Loan Association v. United
States, 731 F.2d 1181, 1183 (5th Cir. 1984); FMR Corp. & Subs. v.
Commissioner, supra at 426; Connecticut Mut. Life Ins. Co. &
Consol. Subs. v. Commissioner, 106 T.C. 445, 453 (1996); see also
In re Federated Dept. Stores, Inc., 171 Bankr. 603 (S.D. Ohio
1994). Recognizing income concomitantly with the recognition of
the related expenses is a goal of our income tax system, and a
proper matching is achieved when an expense is deducted in the
taxable year or years in which the related income is recognized.
See Newark Morning Ledger Co. v. United States, 507 U.S. 546, 565
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