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 Rev. Rul. 67-15

1967-1 C.B. 71

Section 6323 -- Priority of Liens

Sec. 248

Full Text

Rev. Rul. 67-15

Organizational expenditures, which a taxpayer properly elects to amortize and deduct currently for Federal income tax purposes under section 248(a) of the Internal Revenue Code of 1954, may be so deducted even though such expenditures are reflected on the taxpayer's books as capital expenditures. Such treatment is similar to that set forth in Revenue Ruling 58-78, C.B. 1958-1, 148, concerning the treatment of research and experimental expenditures which a taxpayer elects to treat as not chargeable to capital account under section 174 of the Code. As therein pointed out, the requirements of section 1.446-1(a)(1) of the Income Tax Regulations are also applicable in the case of expenditures so treated.