- 100 - however, arguing against what appears to be the rigid approach of the majority that, if the taxpayer’s method of accounting for overhead is to deduct all overhead that does not increase on account of capital activities, such method of accounting clearly reflects income and, thus, must be accepted by respondent. I can do no better than to close with the majority’s own words: In our minds, an expenditure that produces both a current and long-term benefit is neither 100 percent deductible nor 100 percent capitalizable. Instead, regardless of whether the expenditure’s primary or predominant purpose is to benefit significantly the business’ current operation, on the one hand, or its long-term operation, on the other hand, the expenditure is capital in nature to the extent that it produces a significant long-term benefit and deductible to the remaining extent. * * * Majority op. p. 61. WHALEN and BEGHE, JJ. agree with this concurring in part and dissenting in part opinion. 2(...continued) such acquisitions was that associated with the need to distinguish between acceptable and unacceptable risks; i.e., the credit analysis activities. Put simply, the hunt was essential to the capture.Page: Previous 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100 101 102 Next
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