Extract to table

Unlike organizational expenses, for which a statutory amortization election is available, syndication expenses must be capitalized and receive no tax benefit during the life of the partnership

Under IRC §263 and the regulations thereunder, costs that are incurred in connection with the acquisition of a trade or business — including investigatory costs, legal and accounting fees, and other costs that "facilitate" the acquisition — must be capitalized as part of the cost of the acquisition

The abandonment must be evidenced by an "identifiable event" — a concrete act or occurrence that demonstrates the taxpayer's decision to abandon the transaction

263(a)-5, amounts paid to facilitate an acquisition of a trade or business must be capitalized, and insurance premiums incurred in connection with the acquisition are generally treated as facilitative costs