David J. Lychuk and Mary K. Lychuk, et al. - Page 32




                                       - 29 -                                         
               As to the overhead expenses, we conclude and hold                      
          differently.  Those expenses are capital expenditures to the                
          extent that they originated in ACC’s acquisition process, or, in            
          other words, were directly related to ACC’s anticipated                     
          acquisition of installment contracts.  We are unable to find that           
          such was the case.  None of these routine and recurring expenses            
          originated in the process of ACC’s acquisition of installment               
          contracts, nor, in fact, in any anticipated acquisition at all.             
          ACC would have continued to incur most of these expenses in the             
          ordinary course of its business had its business only been to               
          service the installment contracts.  The items of rent and                   
          utilities, for example, were generally fixed charges which had no           
          meaningful relation to the number of credit applications analyzed           
          (or the number of installment contracts acquired) by ACC.  Nor              
          did the printing expense have any such meaningful relation.  In             
          fact, ACC’s printing costs were less in 1994 than in 1993, even             
          though ACC analyzed 18.3 percent more credit applications (and              
          acquired 18.3 percent more installment contracts) in 1994 than in           
          1993.  Although ACC’s telephone and computer costs did increase             
          in 1994 from the prior year, we are unable to discern from the              
          record any direct relationship between that increase and the                
          increase from the prior year in credit applications analyzed                
          and/or installment contracts acquired so as to require                      
          capitalization of those costs.                                              






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