- 26 - 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 expensePage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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