§1621

The FASIT Rules The FASIT rules were enacted pursuant to section 1621(a) of the Small Business Job Protection Act of 1996, Pub.

The sole issue for decision is whether petitioner may deduct $2,483,91 6 D JUN 1 4 2010 - 2 - deposited with an insurance company as an insurance premium under section 1621 for 2004 .2 We hold that it may not .

The questions in this case are: Served 04/12/23 2 [*2] • Is the $875,000 the Gages paid to settle with HUD deductible as an ordinary and necessary business expense under section 1621 for the tax year 2012?

Section 274(d) provides that no deduction shall be allowed with respect to any listed property defined in section 280F(d)(4), unless the taxpayer substantiates: the amount ofthe expense, the time and place ofthe use ofthe property, the business purpose ofthe expense, and the business relationship to the taxpayer ofthe property

Woody is entitled under section 1621 to deductions claimed on his 2004 Schedule C, Profit or Loss From Business .

The issues for decision are: (1) Whether the costs petitioner incurred in starting new regulated investment companies during the years in issue are deductible as ordinary and necessary business expenses under section 1621 or must be capitalized; and (2) if the costs are capital expenditures, whether petitioner is entitled to deduct an amortized portion of such costs under section 167.