- 2 - 1992 and 1993, respectively. After a concession,1 the issues for decision are: (1) Whether Vanalco may deduct or must capitalize the costs of replacing the linings of its aluminum reduction cells. We hold these costs must be capitalized. (2) Whether Vanalco may deduct or must capitalize the costs of replacing substantial portions of the brick floors of its cell rooms with Fondag cement. We hold these costs must be capitalized. (3) Whether Vanalco may deduct or must capitalize the cost of replacing a portion of its ingot plant roof. We hold this cost may be deducted. Background This case was submitted fully stipulated under Rule 122.2 The stipulation of facts and the attached exhibits are incorporated herein by this reference. Vanalco is an S corporation whose principal office was located in Vancouver, Washington, at the time the petition was filed. Petitioner, Richard L. Smith, whose mailing address was Lexington, Massachusetts, at the time he filed the petition, is Vanalco's tax matters person. 1The parties agree that $47,091 of the adjustment in the 1992 FSAA is not in dispute. 2Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. All dollar amounts are rounded to the nearest dollar.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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