John J. Reichel - Page 1

                                   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             
                    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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