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must be capitalized. In the year at issue, Vanalco removed and
replaced approximately 10.6 percent of the plant roof. Vanalco
not only replaced the roofing material, which provides protection
from the rain, but also the decking that supports the roofing
material. Therefore, the replacement included part of the roof
structure.
There is no evidence that substitution of the 2- by 6-inch
wood decking for the corrugated metal provided a functional
improvement to the roof or materially added to the value of the
property, within the meaning of the regulations. See Oberman
Manufacturing Co. v. Commissioner, 47 T.C. 471, 482 (1967). Nor
is there evidence to support a finding that replacement of a
portion of the roof decking would appreciably prolong the life of
the property. The facts do not support a finding that the
purpose of the repair was to put the roof in operation; to the
contrary, the facts show that Vanalco was performing ordinary
maintenance to repair leaks as they appeared and to keep the roof
in operating condition over its probable useful life. See id.;
Hable v. Commissioner, T.C. Memo. 1984-485.
Accordingly, we find that the cost of repairing the plant
roof is deductible as an ordinary and necessary expense under
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