a taxpayer has both start-up expenditures with respect to such trades or businesses and organizational expenditures with respect to such entity— (A) any election under paragraph (1) shall cover both such start-up and organizational expenditures, (B) the amount of the deduction under paragraph (1)(A) with respect to all such start-up and organizational expenditures shall not exceed the limitation under clause (ii) of paragraph (1)(A), and (C) the amount of such start-up and organizational expenditures remaining after such deduction shall be amortized under paragraph (1)(B). . (c) Conforming amendments (1) (A) Part VIII of subchapter B of chapter 1 is amended by striking section 248. (B) Section 56(g)(4)(D)(ii) is amended by striking Sections 173 and 248 and inserting Section 173 . (C) Section 170(b)(2)(D)(ii) is amended by striking (except section 248) . (D) Section 312(n)(3) is amended by striking Sections 173 and 248 and inserting Sections 173 and 195 . (E) Section 535(b)(3) is amended by striking (except section 248) . (F) Section 545(b)(3) is amended by striking (except section 248) . (G) Section 834(c)(7) is amended by striking (except section 248) . (H) Section 852(b)(2)(C) is amended by striking (except section 248) . (I) Section 857(b)(2)(A) is amended by striking (except section 248) . (J) Section 1363(b)(3) is amended by striking section 248 and inserting section 195 . (K) Section 1375(b)(1)(B)(i) is amended by striking (other than the deduction allowed by section 248, relating to organization expenditures) . (L) The table of sections for part VIII of subchapter B of chapter 1 is amended by striking the item relating to section 248. (2) (A) Section 709 is amended to read as follows: 709. Treatment of syndication fees No deduction shall be allowed under this chapter to a partnership or to any partner of the partnership for any amounts paid or incurred to promote the sale of (or to sell) an interest in the partnership. . (B) The item relating to section 709 in the table of sections for part I of