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

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11. Cost of railroad rolling stock even if amortizable under Section 184 of the Code. 12. Advertising costs which result in the acquisition of an asset having a useful life substantially beyond the taxable year. See A. V. Simonson, 5 T.C.M. 718 (19x6) (cost of a promotional film not currently deductible). 13. Cost of trucks based at a trucking terminal facility with respect to the terminal facility. Treas. Reg. § 1.103-10~(f), Example (11). Compare Rev. Rul. 80-12 (expenditures for trucks are not capital expenditures because they are not allocable to any specific facil- ity). 14. Expenditures for equipment or machinery which is moved into the county or municipality within three years of the bond-issue; however, -only if the expenditures for the equipment are made within the six-year period. Treas. Reg. §1.103-10(f), Example (l2}. 15. Cost of molds used to manufacture custom plastic pro- ducts wits respect to the manufacturing facility, re- gardless of whether the manufa~t~urer or the customers take title to the molds, if the molds have a useful life substantially beyond the end of the taxable year. Rev. Rul. 77-224, 1977-1 C.B. 25~: 16. If the principal user of a facility orders equipment for~the facility from a manufacturer, expenditures paid or incurred by the manufacturer are considered to have been incurred concurrently by the principal user. The amount which must be taken into account as a capital expenditure is determined by multiplying (a) the total purchase price payable for the equipment by the prin- cipal user times (b} the percentage of the manufactur- er's total expenditures paid within three years of the bond issue. Rev. Rul. 78-347, 1978-2 C.B. 101. See also Rev. Rul. 74-485, 1974-2 C.B. 32 (capital expendi- tures by construction contractor attributed to prospec- tive owner of building). Note that merely placing the purchase order or entering the construction contract does not incur any capital expenditure by itself. _ - 1 17. Cost of timber incurred under a pay-as-cut timber con- tract when the timber is cut. Rev. Rul. 76-132, 1976-1 C.B. 16.