section 212 of the internal revenue code is the deduction provision for investment expenses. in addition to being an expense and satisfying elements 1-4 above, expenses are deductible as an investment activity under section 212 of the internal revenue code if they are (1) for the production or collection of income, (2) for the management, conservation, or maintenance of property held for the production of income, or (3) in connection with the determination, collection, or refund of any tax.