- 28 - interest expense should be treated as estimated construction costs and available for allocation under the alternative cost method. In Haynsworth, the taxpayer included interest expense in their estimate of anticipated development costs for purposes of computing cost-of- goods-sold, but, as a result of payment of the mortgage on the property, the taxpayer eliminated the interest from its adjusted estimates. Petitioners claim that Haynsworth indicates a long accepted practice of including interest expense in the estimated costs of common improvements. Treatment of the interest expense was not at issue in Haynsworth. The interest expense mentioned in Haynsworth was removed from the total estimated costs in a year before the years in dispute. We reject petitioners’ argument that interest expense should be included in estimated construction costs based on Haynsworth or some accepted practice regarding estimated interest expense. Rev. Proc. 92-29, 1992-1 C.B. 748, provides an alternative to the economic performance rules under section 461(h) for determining when estimated construction costs may be included in the bases of lots sold. In enacting the economic performance rule, Congress was concerned that allowing taxpayers to take current deductions for future obligations overstated the true costs because the time value of money was not taken into account.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
Last modified: May 25, 2011