As employers plan for paying various health care reform fees, one question that arises is whether the fees owed are tax deductible.  In particular, it has been unclear whether the fees paid pursuant the Affordable Care Act to fund the Patient-Centered Outcomes Research Institute (“PCORI”) would be deductible business expenses under Section 162 of the Internal Revenue Code (the “Code”).  On June 7, 2013, the Office of the Chief Counsel of the IRS released a memorandum concluding that, in general, the payment of the PCORI fee should be tax deductible as an ordinary business expense.