- 7 - and 1994) therefore are not subject to capitalization under the rules of section 263A or the Treasury regulations thereunder. Petitioner’s adjusted basis in the Longport property, however, will include the property’s purchase price ($106,000) reduced by allowed or allowable depreciation. See secs. 1011, 1012, 1016. Pursuant to section 263, “any amount paid out for * * * permanent improvements or betterments made to increase the value of any property” must be capitalized. This includes any amount paid or incurred which adds to the value, or substantially prolongs the useful life, of property owned by the taxpayer. See sec. 1.263(a)-1(b), Income Tax Regs. However, amounts paid or incurred for incidental repairs and maintenance of property are not subject to capitalization. See id. Incidental repairs and maintenance expenses do not materially add to the value of the property nor appreciably prolong its useful life, but merely keep it in an ordinarily efficient operating condition. See sec. 1.162-4, Income Tax Regs. Respondent argues that all of the expenses characterized as “Improvements and Repairs” by petitioner constitute incidental repairs and maintenance which should be treated as ordinary and necessary expenses under section 162. After reviewing the record, however, we feel that there is sufficient evidence to indicate that petitioner completed various projects and expended significant amounts that materially added value to the propertyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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