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property"(emphasis added). S. Rept. 99-313, at 140 (1986), 1986-
3 C.B. (Vol. 3) 1, 140.
In sum, petitioner has conceded that although development of
the San Bernardino parcels was deferred by adverse economic
conditions, he acquired and held those parcels intending to
develop (i.e., produce) them. Because the real estate taxes at
issue are expenses petitioner incurred that are allocable to
those properties, he must capitalize those expenses under section
263A.
In reaching our conclusion herein, we have considered all
arguments made by petitioner for a contrary result, and, to the
extent not mentioned above, find them to be irrelevant or without
merit. To reflect respondent's concessions,
Decision will be entered
under Rule 155.
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