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here, tax practitioners were concerned that, because forgiveness of a PPP loan does not cause the borrower to recognize cancellation of indebtedness income, if a taxpayer paid otherwise deductible expenses using the proceeds of a PPP loan that is forgiven, those expenses would not be deductible for federal income tax purposes because the Internal Revenue Code and Treasury regulations provide that no deduction is allowed to the extent the amount is allocable to tax-exempt income. The IRS confirmed these fears by announcing that expenses paid with the proceeds of a PPP loan that is forgiven, or with the proceeds of a PPP loan that the borrower reasonably expects to be forgiven, are not deductible.

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