- 58 -
future benefit. See, e.g., INDOPCO, Inc. v. Commissioner, 503
U.S. 79 (1992); Commissioner v. Idaho Power Co., supra at 13;
Woodward v. Commissioner, supra; Helvering v. Winmill, supra; see
also Ellis Banking Corp. v. Commissioner, T.C. Memo. 1981-123
(citing Woodward v. Commissioner, supra) (fact that a taxpayer
"incurs expenditures * * * on a recurring basis does not ensure
their characterization as ‘ordinary’ if they are incurred in the
acquisition of a capital asset"). The mere fact that an expense
may have been deductible in the credit card cases (or any other
case for that matter) does not necessarily mean that the same
type of expense is ipso facto deductible in another setting such
as the one found in PNC Bancorp, Inc., v. Commissioner, 212 F.3d
822 (3d Cir. 2000). See, e.g., Commissioner v. Idaho Power Co.,
supra at 13.
We also do not believe that the fact that PNC’s loan
origination costs were recurring in nature means that PNC’s
current deduction of them would allow for an appropriate matching
of income and expense. See PNC Bancorp, Inc., v. Commissioner,
supra at 834-835. The Supreme Court stated explicitly in
INDOPCO, Inc. v. Commissioner, supra at 84, that our Federal
income tax system endeavors to match expenses with the related
revenue in the taxable period for which the income is recognized.
The Court stated in Commissioner v. Idaho Power Co., supra at 16,
that “The purpose of section 263 is to reflect the basic
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