Revenue Code of 1986 is amended by adding at the end the following new subsection: (e) Allowance of deduction upon liquidation or disposition (1) Liquidation of a business entity In the case of a complete liquidation by the taxpayer of any corporation, S corporation, or partnership, any start-up and organizational expenditures paid or incurred in connection with such partnership, S corporation, or corporation which were not allowed as a deduction by reason of this section shall be allowed as a loss to the extent provided under section 165. (2) Disposition of trade or business In the case of a complete disposition by the taxpayer of any trade or business, any start-up and organizational expenditures paid or incurred in connection with such trade or business which were not allowed as a deduction by reason of this section (and which are not taken into account under paragraph (1)) shall be allowed as a loss to the extent provided under section 165. . (g) Conforming amendments (1) Section 195(b)(1) of the Internal Revenue Code of 1986 is amended— (A) by inserting (or, in the case of a partnership or S corporation, the entity elects) after If a taxpayer elects , (B) by inserting (or the entity, as the case may be) after the taxpayer in subparagraph (A), and (C) by adding at the end the following flush sentence: In the case of a partnership or S corporation, the election under the preceding sentence shall be made at the entity level. . (2) Section 195(b)(2) of such Code is amended— (A) by striking amortization period.— In any case and inserting the following: amortization period.— (A) In general In any case