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decision to assume the deposit liabilities of a failed savings
association. Metrobank’s management obviously made a business
decision to pay the two fees to insure the assumed deposit
liabilities with its regular insurer, the BIF; management decided
not to forgo the fees, merge under the second exception to the
moratorium, and insure the deposit liabilities with the SAIF.
The BIF’s annual insurance premiums were less expensive than
those of the SAIF, and Metrobank, being a participant in the BIF,
was obviously more familiar with its requirements. Although
respondent observes correctly that Metrobank could have avoided
the fees by assuming the deposit liabilities through a merger,
Metrobank chose for business reasons not to do so. We decline to
second-guess that business judgment. Under the facts herein, the
exercise of such a sound and reasonable business practice under
which a taxpayer such as Metrobank acts to minimize its recurring
operating costs is not a significant future benefit that requires
capitalization of the related nonasset-producing expenditures.
Cost saving expenditures such as this, which are incurred in the
process of fulfilling an everyday sound and reasonable business
practice, as opposed to effecting a change in corporate
structure, qualify for current deductibility under section
162(a). See T.J. Enters., Inc. v. Commissioner, 101 T.C. 581,
589 (1993) (“Expenditures designed to reduce costs are * * *
generally deductible.”), and the cases cited therein. This is
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