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We recognize that the Court in Perlmutter v. Commissioner,
44 T.C. at 403-405, required the taxpayer there to capitalize a
portion of his utilities as sufficiently connected to a capital
transaction. In that regard, the Perlmutter case is
distinguishable from the case at hand in that the Perlmutter case
preceded Woodward v. Commissioner, supra, and the related process
of acquisition test. We also distinguish the printing costs at
hand from the printing costs in A.E. Staley Manufacturing Co. &
Subs. v. Commissioner, 119 F.3d at 492-493, the latter of which
we and the Court of Appeals for the Seventh Circuit considered as
associated with a capital transaction. The printing costs there,
unlike those here, were required to be incurred by the taxpayer
so as to facilitate communication with shareholders and others in
connection with the transaction. See A.E. Staley Manufacturing
Co. & Subs. v. Commissioner, 105 T.C. at 180, 197.
Respondent argues that ACC’s payment of the overhead
expenses produced for it a significant future benefit requiring
capitalization under INDOPCO, Inc. v. Commissioner, 503 U.S. 79
(1992). We disagree. On the basis of our discussion above, we
conclude that any future benefit that ACC realized from these
expenses was incidental to its payment of them so as not to
require capitalization on that theory. See id. at 87-88.
Petitioners argue that the salaries and benefits are ipso
facto deductible because they are the routine, recurring expenses
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