- 11 - Section 274(e) is entitled “Specific Exceptions to Application of Subsection (a)”. (Emphasis supplied.) Likewise, the legislative history contains references to “exceptions” in describing section 274(e)’s subsections. See H. Rept. 1447, supra, 1962-3 C.B. at 428; S. Rept. 1881, supra, 1962-3 C.B. at 742. More particularly, in connection with section 274(e), the legislative history contains the following statement: The bill contains nine exceptions to the general disallowance provision * * *. Where an expense falls within one of the enumerated exceptions, the item will continue to be deductible to the same extent as allowed by existing law. H. Rept. 1447, supra, 1962-3 C.B. at 428; S. Rept. 1881, supra, 1962-3 C.B. at 742. Accordingly, section 274(e) was intended to except certain categories of deduction from the effect of section 274. Subsequent legislative history also references subsection 274(e) as providing for exceptions. See H. Rept. 99-426 (1985), 1986-3 C.B. (Vol. 2) 1, 118. (“If an exception [from subsection 274(e)] applies, the entertainment expenditure is deductible if it is ordinary and necessary and if any applicable section 274(d) substantiation requirements are satisfied.”) Collaterally, and by way of comparison, section 274(e)(9), concerning deductions for expenses for nonemployees, contains the “to the extent that” language. The legislative history concerning that subsection references subsection (e)(9) as an exception. See S. Rept. 96-498 (1979), 1980-1 C.B. 517, 545-546.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011