- 38 - expenditures”); Ellis Banking Corp. v. Commissioner, T.C. Memo. 1981-123 (“Nor would the fact that petitioner was engaged in the business of acquiring bank stock entitle it to deduct such expenditures if the bank stock was a capital asset and the expenditures were incurred in the acquisition thereof. Helvering v. Winmill, supra.”). We also apply the case of Commissioner v. Idaho Power Co., 418 U.S. 1 (1974), revg. 477 F.2d 688 (9th Cir. 1973), revg. T.C. Memo. 1970-83. There, the taxpayer was a public utility engaged in the production, transmission, and sale of electricity. Throughout its long existence, the taxpayer regularly and routinely constructed additional transmission and distribution facilities using its own equipment and hundreds of its own employees. Respondent determined that the taxpayer had to capitalize the depreciation on its equipment to the extent used in the construction project. The Supreme Court agreed. The Court noted that a goal of Federal income tax accounting is to match income with the related expenses and observed that “‘It has long been recognized, as a general matter, that costs incurred in the acquisition * * * of a capital asset are to be treated as capital expenditures.’” Id. at 12 (quoting Woodward v. Commissioner, supra at 575; ellipsis in original). Further, the Court noted: “there can be little question that other construction-related expense items, such as tools, materials, andPage: Previous 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 Next
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