08-10-1982 Industrial Development Corporation Board of Directors Meeting

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during the temporary period). See also Treas. Reg. §1.266-1(b)(1)(iv) (taxpayer permitted to capitalize "any other taxes and carrying charges with respect -to property, which in the opinion of the Commissioner, are, under sound accounting principles, chargeable to capital account"). 3. Issuance costs (underwriting fees, legal fees, printing costs, etc.); but, of course, only if paid other than out of~the bond proceeds. Rev. Rul. 77-234, 1977-2 C.B. 39.~ 4. Asnounts~ expended for securing a copyright and plates that remain the property of the person making the pay- ments. See Treas. Reg. §1.263(x)-2_(b). 5. Cost of defending or-perfecting title to property. See Treas. Reg. §1-263(x)-2(c). 6. Amounts expended for architect's services. See Treas. . Reg. §1.263(x)-2(d). ~ - 7. A corporation's cash acquisitiog of stock of another corporation followed by a liqu3 elation of the acquired corporation to which Section 334(b)(2) of the Code ap- plies is in substance an .acquisition of underlying as- sets, and, therefore is a capi~i expenditure with re- spect to the acquired corporation's facilities to--th~ extent of the percentage of the corporation's fixed assets located in the county (or incorporated munici- pality). The capital expenditure, however, is reduced by the amount expended by the acquired corporation from proceeds of xn outstanding prior small issue for depre- ciable tangible assets located in the county (or incor- porated municipality). LTR 7916021. 8. Commissions paid in purchasing stock as described in "5." above. See Trexs. Reg. §1.263(x)-2(e). 9. Cost of goodwill or a covenant not to compete in con- nection with the acquisition of the assets of a going concern. Rev, Rul. 81-56, 1981-8 I.R.B. 7; Rev. Rul. 81-55, 1981-8 I.R.B. 6. See Treas. Reg. §1.263(x)-2(h) 10. Trademark and tradename expenditures even though amor- tizable under Section 177 of the Code.