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amortized over the life of the capital asset so
acquired. * * * [Emphasis added.]
The point is not whether there is only one capital asset or many
capital assets to which expenses may be attached and capitalized.
Rather, the point is that to require capitalization of what are
otherwise routine and recurring ordinary and necessary expenses,
the expenses must be directly linked and associated with very
specific and identifiable capital assets.
(4) Services relating to ACC’s credit investigations that
were performed by ACC employees simply constituted investigatory
activities and as such the related salaries and overhead expenses
should be currently deductible. See Wells Fargo & Co. & Subs. v.
Commissioner, 224 F.3d 874, 887-888 (8th Cir. 2000), affg. in
part and revg. in part Norwest Corp. & Subs. v. Commissioner, 112
T.C. 89 (1999).
(5) Quite contrary to a possible reading of the majority
opinion (see Ruwe, J., concurring op. p.79), ACC’s primary and
underlying business activity is not the “purchase” of installment
loans. Rather, it is the “holding” of those loans and the
associated provision of funds to debtors and the credit
intermediation relating thereto (and all that is encompassed
within credit intermediation) that ACC provides that constitute
ACC’s primary, dominant, and underlying business activity.
Presumably, the amount of ACC’s income and profit in any one
year relates primarily to its annual cost of funds and to the
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