Vanalco, Inc., a Delaware S Corporation, Richard L. Smith, Tax Matters Person - Page 15




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          often extend beyond the current year.  See United States v.                 
          Wehrli, supra.                                                              
               The distinction between repairs and capital improvements has           
          also been characterized as follows:                                         
                    The test which normally is to be applied is that                  
               if the improvements were made to "put" the particular                  
               capital asset in efficient operating condition, then                   
               they are capital in nature.  If, however, they were                    
               made merely to "keep" the asset in efficient operating                 
               condition, then they are repairs and are deductible.                   
               [Moss v. Commissioner, 831 F.2d 833, 835 (9th Cir.                     
               1987) (quoting Estate of Walling v. Commissioner, 373                  
               F.2d 190, 192-193 (3d Cir. 1967), revg. and remanding                  
               45 T.C. 111 (1965)), revg. T.C. Memo. 1986-128.]                       
          See also Illinois Merchants Trust Co. v. Commissioner, 4 B.T.A.             
          103, 106 (1926) ("In determining whether an expenditure is a                
          capital one or is chargeable against operating income, it is                
          necessary to bear in mind the purpose for which the expenditure             
          was made.").                                                                
               In Plainfield-Union Water Co. v. Commissioner, 39 T.C. 333,            
          338 (1962), the Court articulated a test (the Plainfield-Union              
          test) for determining whether an expenditure is capital by                  
          comparing the value, use, life expectancy, strength, or capacity            
          of the property after the expenditure with the status of the                
          property before the condition necessitating the expenditure                 
          arose.  See Norwest Corp. & Subs. v. Commissioner, 108 T.C. 265,            
          279-280 (1997).                                                             








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