
$72,000. Note that deducting the potential $80,000 dividends received
deduction from taxable income does not generate a net operating
loss. Accordingly, the taxable income limit is not avoided. N
Organizational Expenditures
Corporations amortize qualifying organizational costs over 180 months, and there is no
upper limit to the amount of qualifying costs t hat can be amortized. Corporations can
elect to deduct up to $5,000 of organizational costs in the year they begin business.
The $5,000 amount is reduced by each dollar of organizational expenses exceeding
$50,000. Costs not expensed as part of the first-year election to expense are amortized rat-
ably over the 180-month period beginning with the month the corporation begins busi-
ness. Generally, organizatio nal expenditures that qu alify for amortization include legal
and accounting services incident to organization, expenses of temporary directors and
organizational meetings, and fees paid to the state for incorporation. Expenses such as
the cost of transferring assets to the corporation and expenses connected with selling
the corporati on’s stock are not organizational expend itures and, therefore, are not sub ject
to amortization.
EXAMPLE Coco Bola Corporation, an accrual-basis, calendar-year taxpayer,
incurred $500 in fees to the state for incorporation, legal and
accounting fees incident to the incorporation of $1,000, and tempo-
rary directors’ expenses of $300. Assuming the corporation does not
make an election to expense in the first year, the total $1,800 ($500 þ
$1,000 þ $300) may be amortized over 15 years at a rate of $10 per
month ($1,800/180 months). If the corporation began operations on
June 1, 2010, $70 ($10 per month 7 months) may be deducted for
organizational expenditures for 2010. Alternatively, the corporation
could elect to deduct the full $1,800 of organization costs in the first
year of business. N
Charitable Contributions
Corporations are allowed a deduction for contributions to qualified charitable organiza-
tions. Generally, a deduction is allowed in the year in which a payment is made. If, how-
ever, the directors of a corporation which maintains its books on the accrual basis make a
pledge before year-end and the payment is made on or before the fifteenth day of the third
month after the close of the tax year, the deduction may be claimed in the year of the
pledge.
A corporation’s charitable contribution deduction is limited to 10 percent of taxable
income, computed before the deduction for charitable contributions, net operating loss
carrybacks, capital loss carrybacks, and the dividends received deduction. Any excess con-
tributions may be carried forward to the 5 succeeding tax years, but carryforward amounts
are subject to the 10 percent annual limitation in the carryover years, with the current
year’s contributions deducted first.
EXAMPLE Zircote Corporation had net operating income of $40,000 for 2010
and made a charitable contribution of $6,000 (not included in the
above amount). Also not included in the above operating income
were dividends received of $10,000. The corporation’s charitable
Section 11.3
Special Deductions and Limitations 11-5
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