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Re: continuity post# 368949

Sunday, 04/01/2012 11:29:23 PM

Sunday, April 01, 2012 11:29:23 PM

Post# of 730209
Not a dumb thought continuity because it's actually a complicated tax question but in general reorganization expenses or expenses incurred to effectuate a corporate restructuring, even if not technically under the guise of Sec. 368, are usually nondeductible. Why? There may be other reasons (relating to capital expenditures) but because reorganization expenses have been held nondeductible if they contribute to creating or enhancing a long-term asset (the corporation) or produce significant benefits lasting beyond the current tax year.

What they're saying is there wouldn't be a reorganized company had they not spent those professional fees.

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