Stanley M. Kurzet and Anne L. Kurzet - Page 44

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            timber farm constituted a for-profit, business activity with                              
            respect to which the ordinary and necessary expenses are                                  
            deductible under section 162.                                                             

            Capital Costs of Water Reservoir and Pond                                                 
                  Respondent argues that, using a direct-labor percentage,                            
            the percentage of timber farm general expenses that should be                             
            capitalized as part of the capital costs of the water reservoir                           
            and pond on the timber farm should take into account the hours                            
            that petitioner and his two employees worked on the reservoir                             
            and pond and that some portion of the costs relating to the                               
            nonreservoir-unique equipment should be allocated to the                                  
            reservoir and pond and therefore capitalized.                                             
                  We agree with respondent as to the need to include in the                           
            direct-labor percentage (used to allocate general expenses of                             
            the timber farm to the capital costs of the water reservoir and                           
            pond) a factor for petitioner’s and his two employees’ labor on                           
            the reservoir.                                                                            
                  With regard to the direct costs of the nonreservoir-unique                          
            equipment, we do not believe an allocation to the capital costs                           
            of the water reservoir and pond is appropriate.  The evidence is                          
            not compelling that any nonreservoir-unique equipment was used                            
            extensively on the water reservoir or pond.  We do not sustain                            
            this adjustment.                                                                          







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