ABC Software Company sells software and hardware for computers. The federal government brings an antitrust action against ABC seeking divestiture of ABC's hardware division. As a result of a court ordered divestiture, ABC and the federal government agree to a plan of divestiture that requires ABC to organize a subsidiary to receive the divested assets and to distribute the stock of the subsidiary to its shareholders. During 2016, ABC pays $400,000 to various independent contractors for the following services: identifying assets to be transferred to the subsidiary, organizing the subsidiary, structuring the transfer of assets to the subsidiary to qualify as a tax-free transaction to ABC, and distributing the stock of the subsidiary to the stockholders. How should ABC treat the $400,000 in costs? Explain with references to primary sources.