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during the production period. This is evident when we examine
section 263A(f), which provides a narrow exception under which a
particular category of indirect production costs, namely
interest, does not have to be capitalized until the production
period begins. There would be no need for this exception if
capitalization were never meant to apply until taxpayers actually
started the production process. As we noted in Von-Lusk v.
Commissioner, supra at 213 (quoting Weinberger v. Hynson,
Westcott & Dunning, Inc., 412 U.S. 609, 633 (1973)):
if no costs were to be capitalized until the beginning
of the "production period," then section 263A(f)(1)(A)
would be superfluous. Such a construction "offends the
well-settled rule of statutory construction that all
parts of a statute, if at all possible, are to be given
effect."
The legislative history of section 263A also supports this
reading. In describing the reasons for enacting section 263A,
the relevant section of the House report is headed,
"Preproduction costs" and states the concern that then-existing
rules "may allow costs that are, in fact, costs of producing
property to be deducted currently". H. Rept. 99-426, at 625
(1985), 1986-3 C.B. (Vol. 2) 1, 625. While headings are not
compelling evidence of meaning in themselves, the corresponding
section of the Senate report clarifies and reenforces this
analysis. That section is headed "Production, acquisition, and
carrying costs" (emphasis added) and expresses the intent that "a
single, comprehensive set of rules should govern the
capitalization of costs of producing, acquiring, and holding
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