- 9 - component materials of the depreciable property, the costs of labor or other elements involved in its construction and installation, or costs attributable to the acquisition of the property. Sec. 1.174-2(b)(4), Income Tax Regs. An example in subparagraph (4) is that of a taxpayer who undertakes to develop a new machine for use in his business. The taxpayer expends a total of $30,000 on the project, of which $10,000 represents the actual costs of material, labor, etc., to construct the machine, and $20,000 represents research costs that are not attributable to the machine itself. In this example, the $20,000 research costs are deductible, but the $10,000 costs are not deductible and must be charged to the asset account (the machine). In this case, petitioner's payment of $7,000 for the Porsche engine represented the cost of an asset that was of a character subject to an allowance for depreciation and that was used in connection with research or experimentation. Since the $7,000 was for the acquisition of such an asset, that amount is not deductible as a research or experimentation expense. Sec. 1.174- 2(b)(1), (2), (3), and (4), Income Tax Regs. All other expenses petitioner incurred in connection with the enhancement of the engine represented deductible research or experimentation expenses, and, indeed, respondent has allowed those expenses as deductions. For the $7,000 acquisition cost, however, the CourtPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011