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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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