This area is clearly not "defined" in any statute or regulation.
Active conduct of a trade or business occurs when the business has begun to function as a going concern and perform the activities for which it is organized. Thus, the question of when a taxpayer has begun the active conduct of a trade or business is a facts and circumstances determination that must be made on a case-by-case basis. Generally, the taxpayer must have begun to function as a going concern and perform the activities for which it was organized in order for the start-up period to end .
The date on the SS-4 in general will have no bearing on when the trade or business actually began. This is an estimate only. The IRS will look at the substance of the situation over the form.
Amortization of the Section 195 and 248 costs will run hand in hand. Amortization for both begin as noted above.
*A reminder that posts in a forum such as this do not constitute tax advice.
Also keep in mind the date of replies, as tax law changes.
