Sutherland Lumber-Southwest, Inc. - Page 11




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               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.           





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