in connection with a liquidation to which paragraph (1) applies) may be deducted to the extent allowable under section 165. For purposes of this paragraph, in the case of any deduction allowed under subsection (b)(1) with respect to both start-up and organizational expenditures, the amount treated as so allowed with respect to start-up expenditures shall bear the same ratio to such deduction as the start-up expenditures taken into account in determining such deduction bears to the aggregate of the start-up and organizational expenditures so taken into account. . (b) Organizational expenditures Section 195(d) of such Code, as redesignated by subsection (a), is amended by adding at the end the following new paragraphs: (3) Organizational expenditures The term organizational expenditures means any expenditure which— (A) is incident to the creation of a corporation or a partnership, (B) is chargeable to capital account, and (C) is of a character which, if expended incident to the creation of a corporation or a partnership having an ascertainable life, would be amortizable over such life. (4) Application to certain disregarded entities In the case of any entity with a single owner that is disregarded as an entity separate from its owner, this section shall be applied in the same manner as if such entity were a corporation. . (c) Election Section 195(e)(2) of such Code, as redesignated by subsection (a), is amended to read as follows: (2) Partnerships and S corporations In the case of any partnership or S corporation, the election under subsection (b) shall be made (and this section shall be applied) at the entity level. . (d) Conforming amendments (1) (A) Part VIII of subchapter B of chapter 1 is amended by striking section 248 of such Code (and by striking the item relating to such section in the table of sections of such part). (B) Section 170(b)(2)(D)(ii) of such Code is amended by striking (except section 248) . (C) Section 312(n)(3) of such Code is amended by striking Sections 173 and 248 and inserting Sections