Oliver W. and Edna D. Wilson - Page 35




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          1987); sec. 1.263A-1T(b)(2)(iii)(I), Temporary Income Tax Regs.,            
          52 Fed. Reg. 29378 (Aug. 7, 1987).  The production of real                  
          property includes the rehabilitation or improvement of an                   
          existing building.  Sec. 263A(g)(1); sec. 1.263A-1T(a)(5)(ii),              
          Temporary Income Tax Regs., 52 Fed. Reg. 10061 (Mar. 30, 1987);             
          S. Rept. 99-313, supra at 143, 1986-3 C.B. (Vol. 3) at 143;                 
          Notice 88-99, 1988-2 C.B. 422.                                              
                    (1)  Interest Expense                                             
               Interest paid or incurred during the production period of              
          real property must be capitalized under the special rules of                
          section 263A(f).  Sec. 263A(f)(1)(A) and (B)(i), (4)(A)(i).  The            
          interest to be capitalized includes (1) interest on any                     
          indebtedness directly attributable to production expenditures               
          with respect to the real property, and (2) interest on any other            
          indebtedness to the extent that the taxpayer’s interest costs               
          could have been reduced if production expenditures had not been             
          incurred.  Sec. 263A(f)(2); sec. 1.263A-1T(b)(2)(iv)(A) and (B),            
          Temporary Income Tax Regs., 52 Fed. Reg. 10063 (Mar. 30, 1987).             
          The production period covers the period (1) beginning on the date           
          on which production of the real property begins and (2) ending on           
          the date on which the real property is ready to be placed in                
          service.  Sec. 263A(f)(4)(B); sec. 1.263A-1T(b)(2)(iv)(A),                  
          Temporary Income Tax Regs.                                                  








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