In technical advice memorandum 202004010 (the TAM), the United States (US) Internal Revenue Service (IRS or Service) ruled professional and administrative fees paid by a Target corporation in connection with the acquisition of its stock by Taxpayer did not create a separate and distinct intangible asset and were not deductible as a loss under Internal Revenue Code1 Section 165 by Target upon the subsequent sale of Target’s stock by Taxpayer.FactsTaxpayer acquired Target’s stock in a taxable reverse triangular merger. As part of the acquisition, Target paid professional and administrative fees to law, accounting, investment and other professional firms and the Securities...