I too read the referenced article yet don't understand why these fees don't meet the 162(a) criteria. Unfortunately I am unable to find tax authority authorizing deduction. These fees are similar to amortized loan costs, which are deductible. Although I came across this explanation "SBA Loan Fees and Taxes and SBA guarantee fees aren't tax-deductible because they transfer the cost of an SBA small business loan from taxpayers to businesses that depend on government funding" I don't agree and still not tax authority derived. And doesn't explain why the payment of these fees aren't "ordinary and necessary expenses."