David C. Hutchinson, et al. - Page 26




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          calculation of a developer’s estimated construction costs for               
          common improvements under the alternative cost method.                      
               We disagree.  We believe that the above specific reference             
          in Rev. Proc. 92-29 to section 263A(f) makes it clear that under            
          the alternative cost method the interest capitalization rule of             
          section 263A(f) applies and prevents the allocation (to a                   
          developer’s cost bases in lots sold in a particular year) of                
          estimated future-period interest expense.  Under section 263A(f),           
          only those interest expenses that are paid or incurred during the           
          production period are to be capitalized in the year paid or                 
          incurred.  Section 263A(f) provides in part as follows:                     

                    SEC. 263A(f) Special Rules For Allocation of Interest             
               to Property Produced by the Taxpayer.--                                
                         (1) Interest capitalized only in certain                     
                    cases.-–Subsection (a) shall only apply to                        
                    interest costs which are–-                                        
                              (A) paid or incurred during the production              
                         period, * * *                                                

               The “paid” or “incurred” requirement of section 263A(f)                
          precludes petitioners’ claim that estimated future-period                   
          interest expense may be estimated and allocated to the basis of             
          lots sold in a particular year under the alternative cost method.           
               Our interpretation is consistent with the general economic             
          performance rule of section 461(g) and (h), under which interest            
          expense is not added to the bases of property until the expense             






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