- 9 - 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.Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011