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With respect to consulting fees, the proper allocation of the amount to be expensed or capitalized and the appropriate amortization periods are determined when a new facility is selected and placed in service.
The taxpayer may select the properties for which the expensing election will be made, as well as the portion of each property's cost to be expensed.(12)
179 deduction is determined without having to prorate the expensed amount by either the period of time the property has been in service during the tax year or the length of the tax year, as in the case of short tax years.