Vanalco, Inc., a Delaware S Corporation, Richard L. Smith, Tax Matters Person - Page 2




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          1992 and 1993, respectively.  After a concession,1 the issues for           
          decision are:  (1) Whether Vanalco may deduct or must capitalize            
          the costs of replacing the linings of its aluminum reduction                
          cells.  We hold these costs must be capitalized.  (2) Whether               
          Vanalco may deduct or must capitalize the costs of replacing                
          substantial portions of the brick floors of its cell rooms with             
          Fondag cement.  We hold these costs must be capitalized.  (3)               
          Whether Vanalco may deduct or must capitalize the cost of                   
          replacing a portion of its ingot plant roof.  We hold this cost             
          may be deducted.                                                            
          Background                                                                  
               This case was submitted fully stipulated under Rule 122.2              
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.                                      
               Vanalco is an S corporation whose principal office was                 
          located in Vancouver, Washington, at the time the petition was              
          filed.  Petitioner, Richard L. Smith, whose mailing address was             
          Lexington, Massachusetts, at the time he filed the petition, is             
          Vanalco's tax matters person.                                               


               1The parties agree that $47,091 of the adjustment in the               
          1992 FSAA is not in dispute.                                                
               2Unless otherwise indicated, all section references are to             
          the Internal Revenue Code in effect for the taxable years at                
          issue, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.  All dollar amounts are rounded to the              
          nearest dollar.                                                             




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