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cleaning devices, in addition to increasing the safety of its
employees. See id.
On the facts of this case, we hold that Vanalco must
capitalize the costs of replacing the brick floors of its cell
rooms with Fondag cement.
The Plant Roof
The plant roof is 122,567 square feet. During the period
1989 through 1994, Vanalco removed and replaced 42,514 square
feet of roof decking and 78,197 square feet of roofing material.
In 1992, Vanalco removed and replaced 12,927 square feet of roof
decking and roofing material.
Petitioner argues that the replacement of the portion of the
roof in the year at issue was only to repair a leak and not part
of a plan of rehabilitation. Respondent argues that the roof
repair was more than patching a few leaks, and that when this
repair is considered with the roof repairs performed in 1989
through 1994, it is evident that Vanalco had a plan to replace
most of its roof over a period of years.
Expenses incurred as part of a general plan of
rehabilitation, modernization, or improvement must be capitalized
even though the same expenses if incurred separately would be
deductible as ordinary and necessary. See United States v.
Wehrli, 400 F.2d at 689; Norwest Corp. & Subs. v. Commissioner,
108 T.C. at 280. An asset need not be completely out of service
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