Badger Pipe Line Company - Page 10

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          1990) (cost of moving brewery tanks from seller's plant); Sears             
          Oil Co. v. Commissioner, T.C. Memo. 1965-39 (cost of transporting           
          barges from place of manufacture to taxpayer's place of                     
          business).  In contrast, the cost of moving property already in             
          use by the taxpayer may be a deductible business expense,                   
          although the general plan of rehabilitation analysis applies to             
          moving as well as repair costs.  True v. United States, supra at            
          1209 (and cases cited therein).                                             
               An important factor in determining whether the appropriate             
          tax treatment is immediate deduction or capitalization is the               
          taxpayer's realization of benefits beyond the year in which the             
          expenditure is incurred.  INDOPCO, Inc. v. Commissioner, 503 U.S.           
          79, 87 (1992); United States v. Wehrli, supra at 689.  This,                
          however, is not an absolute rule, since the benefits of                     
          expenditures considered to be currently deductible, such as                 
          repairs, for example, often extend beyond the current year.                 
          United States v. Wehrli, supra.  As stated previously by this               
          Court, "The proper test is whether the expenditure materially               
          enhances the value, use, life expectancy, strength, or capacity             
          as compared with the status of the asset prior to the condition             
          necessitating the expenditure."  Plainfield-Union Water Co. v.              
          Commissioner, 39 T.C. 333, 338 (1962).                                      
               It is clear from the foregoing analysis that whether an                
          expenditure may be deducted or must be capitalized is a question            

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