(a) General rule.— Except as provided in subsection (b), no deduction shall be allowed to the partnership or to any partner for any amounts paid or incurred to organize a partnership or to promote the sale of, or to sell, an interest in such partnership.(b) Deduction of organization fees.—(1) Allowance of deduction.— Pursuant to the regulations prescribed by the Secretary, a partnership may elect that the organizational expenses to promote the sale of, or to sell, an interest in said partnership be allowable as a deduction ratably during a period of not less than sixty (60) months starting with the month in which the partnership begins business.(2) Dispositions before close of amortization period.— In any case in which a partnership is liquidated before the end of the period to which clause (1) refers, any deferred expenses attributable to the partnership which were not allowed as a deduction by reason of this section may be deducted from the gross income of the partnership.(3) Organizational expenses.— For purposes of this section, organizational expenses are expenditures that:(A) Are incident to the creation of the partnership;(B) are chargeable to capital account, and(C) are of

ational expenses.— For purposes of this section, organizational expenses are expenditures that:(A) Are incident to the creation of the partnership;(B) are chargeable to capital account, and(C) are of a character which, if expended incident to the creation of a partnership having an ascertainable life, would be amortized over such life.(4) The Secretary shall establish the application of this section through regulations. History —Jan. 31, 2011, No. 1, § 1071.09, retroactive to Jan. 1, 2011; Dec. 10, 2011, No. 232, § 88.