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or in total disrepair for the general plan of rehabilitation
doctrine to apply. See Norwest Corp. & Subs. v. Commissioner,
supra. Whether a plan exists and whether an item is part of it
are usually questions of fact to be determined by a realistic
appraisal of all the surrounding facts and circumstances,
including the purpose, nature, extent, and value of the work
done. See United States v. Wehrli, supra at 690.
At the time of the roof repair, the plant was in operating
condition and had been for many years. See Keller St. Dev. Co.
v. Commissioner, 37 T.C. 559, 568 (1961), affd. in part and revd.
in part 323 F.2d 166 (9th Cir. 1963); Kaonis v. Commissioner,
T.C. Memo. 1978-184, affd. without published opinion 639 F.2d 788
(9th Cir. 1981). Furthermore, although portions of the roof were
repaired over a period of 5 years, no repairs were made during
1993. Therefore, the repairs during the year at issue were not
part of a continuous process of roof rebuilding. Nor is there
any evidence to support a finding that repairing the plant roof
was done in preparation or as part of a remodeling project. Cf.
Norwest Corp. & Subs. v. Commissioner, supra at 284-285. We
agree with petitioner that the roof repair was not part of a
general plan of rehabilitation.
However, a finding that the roof replacement was not part of
a general plan of rehabilitation does not mean that the
replacement was not an improvement to the plant the cost of which
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