112 T.C. No. 2
UNITED STATES TAX COURT
JOHN J. REICHEL, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23143-97. Filed January 7, 1999.
P, a real estate developer, purchased properties
intending to develop them. He undertook no development
activities on the properties due to adverse economic
conditions. R disallowed P's deductions of the properties'
real estate taxes, determining the taxes must be capitalized
under sec. 263A, I.R.C., as indirect expenses of producing
property.
Held: P must capitalize the tax payments under
sec. 263A, I.R.C.
Timothy W. Tuttle, for petitioner.
Michael H. Salama and Sherri S. Wilder, for respondent.
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