§ 195. Start-up expenditures
(a)
Capitalization of expenditures
Except as otherwise provided in this section, no deduction shall be allowed for start-up expenditures.
(b)
Election to deduct
(1)
Allowance of deduction
If a taxpayer elects the application of this subsection with respect to any start-up expenditures—
(2)
Dispositions before close of amortization period
In any case in which a trade or business is completely disposed of by the taxpayer before the end of the period to which paragraph (1) applies, any deferred expenses attributable to such trade or business which were not allowed as a deduction by reason of this section may be deducted to the extent allowable under section
165.
(c)
Definitions
For purposes of this section—
(1)
Start-up expenditures
The term “start-up expenditure” means any amount—
(d)
Election