- 11 - over 5 years beginning with the year the costs were paid or incurred, as permitted by section 291(b)(2)(B)(i), and through 1985 it included that amount in “qualified investment” (within the meaning of section 46(c)) for purposes of computing investment credit, as permitted by section 291(b)(2)(B)(ii). Cordero also took the total amount capitalized for each year into account in computing the adjustment set forth on Schedule M-1, Reconciliation of Income Per Books with Income Per Return, for “expenses recorded on books this year not deducted on this return”. As noted above, Cordero mistakenly capitalized 20 percent of the mine development expenses reported for 1984, rather than 15 percent, the statutory rate then in effect under section 291(b)(1). The parties agree that petitioner is entitled to increase the aggregate deduction claimed in 1984 by the excess amount capitalized, $1,076,080, as long as petitioner also makes appropriate correlative adjustments to petitioner’s reported investment tax credit for 1984 and to its reported amortization for 1984 through 1988. For each of the taxable years 1987 through 1990, Cordero treated all of its overburden removal costs at the Gillette mine as mine development costs, subject to section 291(b). For each of those years, Cordero capitalized 30Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011