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r <br />7. Amounts expended for architect's services. See Treas. <br />Reg. § 1.263(a)-2(d). <br />8. A corporation's acquisition of stock of another <br />corporation followed by a liquidation of the acquired <br />corporation to which Sectior. 334(b)(2) of the Code <br />applies is in substance ar. acquisition of underlying <br />assets, and, therefore, is a capital expenditure with <br />respect to the acquired corporation's facilities to the. <br />extent of the percentage of the corporation's fixed <br />assets located in the county or incorporated <br />municipality). LTR 7916021 (amount of capital <br />expenditure, however, reduced by the amount expended by <br />the acquired corporation from proceeds of an <br />outstanding prior small issue for depreciable tangible <br />assets located in the county or incorporated <br />municipality); LTR 7946049. This same principle <br />probably applies to a corporation's dualified stock <br />purchase with respect to which an election is made <br />under Section 338 of the Code, as added by the Tax <br />Equity and E'iscal Responsibility Act of 1982. <br />9. Commissions paid in purchasing stock as described in <br />"8." above. See Treas. Reg. § 1.263(a)-2(e). <br />10. Cost of goodwill or a covenant not to compete in <br />connection with the acquisition of the assets of a <br />going concern. Rev. Rul. 81-56, 1981-8 I.R.E. 7; Rev. <br />Rul. 81-55, 1981-8 I.R.B. 6; LTR 810174 (covenant not <br />to compete allocated based or. percentage of principal <br />user's assets in the area covered by the covenant which <br />are located in county or municipality). See Treas. <br />Reg. § 1.263(a)-2(h). <br />11. Cost of other intangible assets with a useful life <br />substantially beyond the taxable year (e•g•, patents, <br />copyrights, customer lists). See Treas. Reg. § 1.167 <br />(a)-3. <br />12. Advertiseng costs which result in the acquisition of an <br />asset having a useful life substantially beyond the <br />taxable year. See A.V. Simcr_sor., 5 T.C.M. 718 (1946) <br />(cost o~ a promotional ~ilm not currently deductible). <br />13. Cost of trucks based at a trucking terminal _`acility <br />with respect to the ter^i^.al _`ac~lity. Treas. Reg <br />§ 1. 103-10(f) , R:{ample ( 11) . Cc:rcar= Rev . Rul. 30-12 <br />-3- <br />-, <br />