- 21 - benefits paid by ACC in connection with its loan origination/ acquisition activities. 2. Professional Fees Capitalization is “consistent with the capitalization arguments presented for the loan origination/acquisition and offering expenses of ACC in [Lychuk].” Respondent argues that “the professional fees at issue were related to ACC’s securing a line of credit with NBD Bank, N.A., and, thus, were similar to the offering expenses incurred in securing the source of borrowing in Lychuk.” Also, like the offering expenses capitalized in Lychuk, they established an intangible asset (a line of credit) that “extended beyond the year in which the fees were incurred.” 3. Timeliness of Respondent’s Concessions a. Loan Origination/Acquisition Costs Respondent’s April 19, 2002, concession that petitioners’ loan origination/acquisition costs for the audit years are deductible, just over 1 month after the issuance of CCN 2002-21, on March 15, 2002 (wherein the IRS announced that it would no longer seek to capitalize employee compensation related to a capital transaction other than bonuses and commissions paid with respect to the transaction), was timely.Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
Last modified: May 25, 2011