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Comparison definition.  Section 162(a) of the Internal Revenue Code allows the deduction of 'all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business.' 26 U. S. C. § 162(a). In contrast, § 263 of the Code allows no deduction for a capital expenditure-an 'amount paid out for new buildings or for permanent improvements or betterments made to increase the value of any property or estate.' § 263(a)(1). The primary effect of characterizing a payment as either a business expense or a capital expenditure concerns the timing of the taxpayer's cost recovery: While business expenses are currently deductible, a capital expenditure usually is amortized and depreciated over the life of the relevant asset, or, where no specific asset or useful life can be ascertained, is deducted upon dissolution of the enterprise. See 26 U. S. C. §§ 167(a) and 336(a); Treas. Reg. § 1.167(a), 26 CFR § 1.167(a) (1991). Through provisions such as these, the Code endeavors to match expenses with the revenues of the taxable period to which they are properly attributable, thereby resulting in a more accurate calculation of net income for tax purposes. See, e. g., ...

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