Andersen Managing Directors Tony Brown and Mary Duffy's article Treatment of R&E Expenditures In Asset Dispositions was recently featured in Tax Notes. In the article, Tony and Mary examine Sec. 174(d) and how it should apply to research and experimentation expenditures. Tony and Mary conclude that Sec. 174(d) should (1) reduce the amount realized from the disposition of property by the adjusted basis of the property (up to the amount realized), and (2) calculate the continued amortization using only the loss disallowed. The issues discussed in this article will have a significant impact on M&A transactions occurring after 2021, directly affecting how much taxable income is generated in such transactions.