This semester, we learned that Congress designed the Code to include various deductions from income. (NOTE: We are not discussing the deductions that may arise from losses.) There are two deductions that are particularly important to corporations:

(1) the Section 162 deduction for business expenses and (2) the dividend-received deduction. How does the IRS generally interpret deductions (i.e., broadly or narrowly)? How do we determine whether a taxpayer is entitled to each of these two deductions? What is the purpose of each of these deductions? How is each calculated, and are there any limits on the deduction? Finally, what generally governs when a taxpayer may take each of these two deductions?

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