- 59 - principle that a capital expenditure may not be deducted from current income. It serves to prevent a taxpayer from utilizing currently a deduction properly attributable, through amortization, to later tax years when the capital asset becomes income producing.” The thrust of these statements, in our minds, is that an expenditure must be deducted in accordance with its own individual identity, regardless of the possible recurrence in the taxpayer’s business of that type of expense. A taxpayer’s income will be distorted if the taxpayer currently deducts a recurring expense that should be capitalized and the amount of that expense fluctuates meaningfully between taxable years. For example, when the amount of such an expenditure increases significantly from one year to the next, the deduction of the expenditure may result in the taxpayer’s income being understated in the first year and overstated in the second, and the profits of the business may appear to be sinking, when in fact it is enjoying great success, or rising, when in fact it may be seriously diminished. See Electric & Neon, Inc. v. Commissioner, 56 T.C. 1324, 1332-1333 (1971), affd. without published opinion 496 F.2d 876 (5th Cir. 1974). Such an inaccurate reporting of this fluctuation thwarts, rather than fosters, “a major objective of efficient tax policy.” Cabintaxi Corp. v. Commissioner, 63 F.3d 614, 619 (7th Cir. 1995), affg. in part, revg. in part, and remanding on another issue T.C. Memo. 1994-316.Page: Previous 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 Next
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