- 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
Last modified: May 25, 2011