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Nor does our reading of section 195 support a contrary
conclusion. Recently, in FMR Corp. & Subs. v. Commissioner,
supra, we addressed the applicability of section 195 in a context
analogous to the setting at hand, holding that section 263(a)
required that the taxpayer capitalize the costs which it incurred
in developing and launching 82 new regulated investment companies
(RIC's). The costs were incurred in a series of activities
starting with the development of the idea for the new RIC and
continuing with the development of the initial marketing plan,
drafting of the management contract, formation of the RIC,
obtaining the board of trustee's approval of the contract, and
registering the new RIC with the SEC and the States in which the
RIC would be marketed. Id. at 413. The taxpayer had argued that
section 195 allowed for the current deductibility of all these
costs because, it asserted, they were incurred in expanding an
existing business. We disagreed. We held that section 195 does
not require "that every expenditure incurred in any business
expansion is to be currently deductible." Id. at 429.
In sum, we hold that DBTC may not deduct any of the disputed
costs because all costs were sufficiently related to an event
that produced a significant long-term benefit. Although the
costs were not incurred as direct costs of facilitating the event
that produced the long-term benefit, the costs were essential to
the achievement of that benefit. We have considered all
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